Family office in IrelandOverview
Ireland is an onshore choice. Families use it because it is an English-speaking, common-law member of the EU and euro area with a broad tax treaty network, a 12.5% trading rate, and a deep fund administration industry in Dublin. It fits Irish families and returning diaspora, international families with European operating businesses who want an EU holding company that banks and counterparties readily accept, and family offices that want to build a regulated fund or co-investment platform. It is not a low-tax jurisdiction for individuals: capital acquisitions tax, the close company surcharge and anti-avoidance rules for personal portfolio investments mean the benefits come from design, not from headline rates. Ireland often works alongside a Luxembourg or Netherlands holding layer, a London investment team, or a Jersey, Guernsey or Isle of Man trust.
There is no Irish family office regime, so the perimeter is set by general financial services law. An entity that provides investment services such as portfolio management or investment advice must normally be authorised by the Central Bank as a MiFID investment firm under the European Union (Markets in Financial Instruments) Regulations 2017, or under the Investment Intermediaries Act 1995 for domestic intermediary business. MiFID II, however, exempts persons providing investment services exclusively to their parent undertakings, subsidiaries or fellow subsidiaries, which is how an office structured within one family's corporate group typically stays outside. Recital 7 of the AIFM Directive confirms that family office vehicles investing the family's private wealth without raising external capital are not alternative investment funds. An office that serves several families, or that manages a vehicle with outside investors, moves into authorisation: initial capital of EUR 75,000, EUR 150,000 or EUR 750,000 under the Investment Firms Regulation, fitness and probity pre-approval of directors and senior managers, and an Irish 'heart and mind'. Offices that act as trustee, director or company secretary for third parties also need authorisation as a trust or company service provider from the Department of Justice under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010.
The core vehicle is usually an Irish private company limited by shares. A holding company can dispose of shareholdings of at least 5% in EU or treaty-country trading subsidiaries held for 12 months free of tax under section 626B of the Taxes Consolidation Act 1997, and from 1 January 2025 qualifying foreign dividends can also be exempt. A family investment company holding a passive portfolio pays 25% on investment income, but as a close company it faces a 20% surcharge on undistributed investment and estate income unless that income is distributed within 18 months, so the economics depend on the family's income tax position. For co-investment and fund-like activity, families use an ICAV under the ICAV Act 2015, an investment limited partnership under the 1994 Act as modernised in 2020, or a Section 110 company for qualifying financial assets of at least EUR 10 million. Irish-resident investors must watch the personal portfolio investment undertaking rules, which tax funds the investor can influence at 60%.
Budget 2027, announced on 6 October 2026, changes the arithmetic. The capital gains tax rate falls from 33% to 31% for disposals from 7 October 2026 (development land stays at 33%); CAT stays at 33% while the Group A threshold for gifts and inheritances from parents rises from EUR 400,000 to EUR 420,000, Group B to EUR 44,000 and Group C to EUR 22,000; and the rate on Irish funds and equivalent offshore funds and life policies falls from 38% to 35% from 1 January 2027. For succession, business relief (90% reduction in the taxable value of qualifying business assets) and discretionary trust tax (6% once-off and 1% annual charges) remain central planning points. Transparency rules have also moved: new regulations in 2026 (S.I. No. 335 of 2026 for trusts and S.I. No. 406 of 2026 for companies) restrict access to the beneficial ownership registers to persons with a legitimate AML/CFT interest, with decisions due within 12 working days from 10 November 2026.
Key benefits
- Onshore EU and euro-area platform with a broad tax treaty network and access to EU directives
- SFO for one family group generally outside Central Bank authorisation under the MiFID group exemption
- Holding company participation exemption on disposals of qualifying subsidiaries and, since 2025, for qualifying foreign dividends
- Full range of regulated vehicles (ICAV, ILP, unit trust, QIAIF) and a deep administration, depositary and audit industry
- English-speaking, common-law system with trusts, a commercial court and established private client advisers
- Lower capital gains tax rate of 31% from 7 October 2026 and higher CAT thresholds under Budget 2027
- Remittance basis for resident but non-domiciled individuals on foreign income and gains not brought to Ireland
Requirements
- Confirm whether the office provides investment services to anyone outside the family's corporate group; if so, obtain MiFID or Investment Intermediaries Act authorisation from the Central Bank
- For a MiFID firm: initial capital of EUR 75,000, EUR 150,000 or EUR 750,000 depending on activities, at least three full-time staff, risk, compliance and internal audit functions, and pre-approval of PCF role holders
- Obtain trust or company service provider authorisation from the Department of Justice before acting as trustee, director or secretary for third parties
- Appoint at least one EEA-resident director to an Irish company, or put in place a bond or show a real and continuous economic link, under the Companies Act 2014
- Hold board meetings and keep central management and control in Ireland where Irish tax residence and treaty access are required
- File beneficial owners with the RBO (companies), with Revenue's Central Register of Beneficial Ownership of Trusts (Irish-resident trusts) and with the Central Bank register (ICAVs, ILPs, unit trusts)
- Apply customer due diligence, source-of-wealth and suspicious transaction reporting under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010
- Classify each entity for CRS and FATCA and report to Revenue; prepare for DAC8 crypto-asset reporting
- Manage close company surcharge, PPIU and Pillar Two exposure (15% minimum for groups with revenue of EUR 750 million or more) in the holding structure
Structure designs
Family holding company for operating businesses
An Irish company holding trading subsidiaries in Ireland, the EU or treaty countries, using the section 626B participation exemption and foreign dividend exemption. Suits entrepreneurial families with European operating groups.
Family investment company
A company owned by parents and children through different share classes, holding a passive portfolio taxed at 25%, with the 20% close company surcharge managed through distributions. Suits Irish-resident families planning gradual succession.
Single-family office services company
A company inside the family group employing the CIO, analysts and finance staff and serving only group entities, relying on the MiFID group exemption. Suits families wanting an in-house team in Dublin.
ICAV or QIAIF family fund
Minimum subscription EUR 100,000 per investor (QIAIF)
A Central Bank-authorised ICAV with an AIFM, depositary and administrator, often with sub-funds for different strategies or branches. Suits families admitting co-investors or seeking an institutional-grade vehicle.
Investment limited partnership
A tax-transparent ILP with a family-controlled general partner for private equity, venture and real asset co-investments. Suits families investing alongside other families and managers.
Discretionary trust for succession
An Irish discretionary trust holding shares in the family companies, subject to 6% once-off and 1% annual discretionary trust tax, or a foreign trust where family members live elsewhere. Suits families separating ownership from control across generations.
Step-by-step process
- 1
Residence, domicile and tax review
Establish the residence and domicile of each family member, the assets involved and the Irish and foreign tax consequences, including CAT, CGT, CFC and PPIU rules.
- 2
Perimeter analysis
Confirm whether the office serves only the family group or third parties, and whether any vehicle is an AIF, to decide on MiFID, AIFM or TCSP authorisation.
- 3
Structure and governance design
Choose holding, investment and fiduciary vehicles and draft the constitution, shareholders' agreement, family charter, investment policy and committee terms.
- 4
Incorporation and registration
Incorporate with the CRO, appoint an EEA-resident director, register for tax with Revenue and file beneficial owners on the RBO or CRBOT.
- 5
Authorisation where required
Prepare the Central Bank key facts document and application, programme of operations, capital plan and fitness and probity questionnaires, or the ICAV and fund authorisation file.
- 6
Banking and operations
Open bank and custody accounts, appoint auditors and administrators, classify entities for CRS and FATCA and set up payroll for local staff.
- 7
Ongoing compliance
File annual and tax returns, manage surcharge and distribution timing, and review the structure after each Finance Act and as the next generation becomes involved.
Typical documents
- Certified passports and proof of address for shareholders, directors and beneficial owners
- Source-of-wealth and source-of-funds evidence for each family member contributing assets
- Personal tax residence and domicile analysis for each family member
- Company constitution and shareholders' agreement, with share class rights
- Trust deed and letter of wishes, where a trust is used
- Group structure chart and description of the activities of each entity
- Central Bank key facts document, business plan and individual questionnaires for PCF roles (if authorisation is needed)
- AML/CFT policies and procedures and MLRO appointment
- Family charter, investment policy statement and investment committee terms
- Bank account opening forms and CRS/FATCA self-certifications
How Legal Wealth helps
Legal Wealth helps families decide whether Ireland should host the holding, investment or fund layer of their office and how it fits with trusts and companies elsewhere. We coordinate Irish solicitors, tax advisers, fund administrators and banks, test the Central Bank and TCSP perimeter before anything is incorporated, model the close company surcharge, CAT and CGT outcomes under Budget 2027, and prepare a discreet source-of-wealth file. Governance documents are drafted around the family's succession plans, and the structure is reviewed whenever family members move. Our approach is compliance-first, so every element is built to withstand Revenue, Central Bank and bank scrutiny.
Enquire with Legal WealthFrequently asked questions
Does a single-family office in Ireland need Central Bank authorisation?
Usually not, if it provides investment services only to companies in the same family group, because MiFID II exempts services provided exclusively to parent undertakings, subsidiaries and fellow subsidiaries. Advising or managing assets for other families, or managing an AIF with outside investors, requires authorisation.
How is a family investment company taxed?
Passive income such as interest, rent and most dividends is taxed at 25%, and chargeable gains at the capital gains tax rate. As a close company it also pays a 20% surcharge on undistributed investment and estate income unless it distributes within 18 months, so the overall result depends on the shareholders' own tax rates.
What did Budget 2027 change?
It cut the capital gains tax rate from 33% to 31% from 7 October 2026, raised the CAT Group A threshold to EUR 420,000, Group B to EUR 44,000 and Group C to EUR 22,000 for gifts and inheritances from that date, and reduced the rate on fund and life policy investments from 38% to 35% from 1 January 2027. The CAT rate remains 33%.
Can a family fund be an ICAV?
Yes. An ICAV authorised by the Central Bank as a QIAIF with a minimum subscription of EUR 100,000 per investor is commonly used where co-investors join. It needs an authorised AIFM, depositary and administrator. A vehicle investing only family wealth without raising external capital is not an AIF and may not need to be regulated.
Is beneficial ownership information public in Ireland?
No. Under 2026 regulations (S.I. No. 406 of 2026 for companies and S.I. No. 335 of 2026 for trusts), access beyond authorities and obliged entities is limited to persons who show a legitimate interest in preventing money laundering, such as journalists, civil society organisations and prospective counterparties, who receive a three-year certificate.
Is there an Irish investor visa?
No. The Immigrant Investor Programme closed to new applications on 15 February 2023. Non-EEA founders can apply under the Start-up Entrepreneur Programme with at least EUR 50,000 of funding for an innovative business, and EU, EEA and Swiss nationals can live in Ireland without permission.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
Sources
- McCann FitzGerald – Ireland as a location for MiFID investment firms 2025
- Revenue – Close companies
- KPMG Ireland – Budget 2027 headlines
- Maples – Irish Budget 2027: implications for Irish and international investors
- Maples – Ireland implements new rules on third-party access to beneficial ownership registers
- Irish Immigration Service – Closure of the Immigrant Investor Programme
