Non-Domiciled in Ireland: Remittance Basis and Crypto

Updated 17 October 2026 · Information only · Not tax or financial advice

Short answer: Revenue's manual says an individual who is resident or ordinarily resident in Ireland but not domiciled is taxable on a remittance basis: generally only foreign income or gains brought into Ireland are taxed. For CGT, section 29(2) TCA 1997 charges residents and ordinarily resident individuals on gains, and section 29(4) disapplies that where the gain comes from disposing of assets "situated outside the State" by an individual not domiciled in the State. Revenue stresses the test is "situated outside the State", not "not situated in Ireland".

The cloud point

The manual says that where a crypto-asset "exists on the cloud" it is not situated anywhere, so it cannot be viewed as "situated outside the State". Where the situs is in dispute, the onus is on the taxpayer to prove where the gain accrued. If the location cannot be confirmed, the gain is chargeable in Ireland based on residency rules.

What this means in practice

• Don't assume holding crypto on a foreign exchange automatically places it outside the State.
• Keep evidence of where the asset was held and why (the manual doesn't list acceptable evidence).
• The usual CGT dates and records still apply (dates, records).

Made-up example

A resident, non-domiciled individual sells crypto held in a self-custody wallet and cannot show any location. Under the manual's wording, the gain is chargeable in Ireland on residency rules, even if the sale proceeds stay abroad.

FAQ

Does this apply to all non-domiciled people?

Only to those resident or ordinarily resident here and not domiciled in the State (per the manual).

Has the remittance basis changed recently?

We did not verify any change.

What we could not verify

Sources (official)

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