Family Office in Ireland: Rules, Costs and Tax in 2026
Ireland has no family office licence or regime: an office needs Central Bank authorisation as a MiFID investment firm if its regular business is providing investment services such as portfolio management to third parties, and the MiFID Regulations 2017 do not apply to services provided only to the office's parent, subsidiaries or sister companies. Companies pay 12.5% on trading income and 25% on non-trading income, close companies pay a 20% surcharge on undistributed investment income, and gifts and inheritances above lifetime group thresholds are taxed at 33% (for children, EUR 420,000 from 7 October 2026: announced in Budget 2027 and listed by Revenue, but still in the Finance (No.2) Bill 2026). Budget 2027 also announced a cut in capital gains tax from 33% to 31% from 7 October 2026, in the same Bill and not yet enacted, and the Immigrant Investor Programme closed to new applications on 15 February 2023. [1, 2, 3, 4, 5, 6, 7, 8]
Best for: Families whose office serves only the family's own group of companies, to which the MiFID Regulations 2017 do not apply, and families moving to Ireland who are not Irish-domiciled and can be taxed on foreign investment income only when it is remitted, who accept 33% gift and inheritance tax above the group thresholds.
At a glance
| Licence | No family office licence; MiFID authorisation unless group or trustee exemption applies |
|---|---|
| Minimum wealth | No wealth minimum in the MiFID Regulations 2017 or Central Bank authorisation guidance |
| Who counts as family | No family definition; group and trustee exemptions, none found for family members |
| Serving several families | Central Bank MiFID authorisation; EUR 75,000 initial capital without client assets |
| Law and courts | Common law (Law Reform Commission); Central Bank regulates; national taxes (Revenue) |
| Substance | No rule for single family offices; MiFID firms need mind and management in Ireland |
| Holding vehicles | Companies, discretionary trusts (6% once plus 1% a year), Irish funds; others not checked |
| Corporate tax | 12.5% trading, 25% non-trading income; 15% for groups from EUR 750 million revenue |
| Family office tax | No family office regime; 20% surcharge on undistributed investment income |
| Personal income tax | Top 40% income tax, 8% USC, 4.35% PRSI; CGT 33% (31% in a Bill); non-dom remittance basis |
| Inheritance tax | 33% above EUR 420,000 for children from 7 Oct 2026 (Bill pending); spouses exempt |
| Wills and succession | Spouse's legal right: half, or a third with children; children can claim under section 117 |
| Residence | Investor programme closed in 2023; Stamp 0 asks for EUR 50,000 individual income a year |
| Time to set up | No company registration time found; MiFID authorisation decided within 6 months |
| Official fees | No official figure found |
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Licence and who qualifies
How is a family office licensed in Ireland?
No family office licence or registration was found in Irish law or on the Central Bank's pages. Under the European Union (Markets in Financial Instruments) Regulations 2017 a person may not act as an investment firm in the State unless authorised (Regulation 5(1)); an investment firm is 'any person whose regular occupation or business is the provision of one or more investment services to third parties', and portfolio management is 'managing portfolios in accordance with mandates given by clients on a discretionary client-by-client basis' (Regulation 3(1)). The Regulations do not apply to persons which provide investment services exclusively for their parent undertakings, their subsidiaries or other subsidiaries of their parent undertakings (Regulation 4(1)(b)), to persons dealing on their own account in financial instruments other than commodity derivatives, under conditions (4(1)(c)), or to a trustee in respect of actions as trustee of a trust, 'unless the principal objective of the trust is to provide investment services to members of the public' (4(1)(n)). No exemption for services to family members as individual clients was found in the Regulations, and the Central Bank's MiFID page and its 2021 authorisation guidance do not mention family offices. The Investment Intermediaries Act 1995, as enacted, covers persons providing investment business services or investment advice to third parties on a professional basis and also excludes services provided only to group companies (section 2(6)(a)), with no family or trustee exclusion; its amended text was not read. [1, 2, 11, 12]
What is the minimum wealth for a family office in Ireland?
No minimum family wealth in the MiFID Regulations 2017 or in the Central Bank's MiFID authorisation guidance: the group exemption in Regulation 4(1)(b) depends only on group relationships, and no family office rule with a wealth test was found. The EUR 75,000 to EUR 750,000 in the Central Bank's guidance is the initial capital an authorised investment firm must hold, not a family wealth minimum; a separate income test applies to residence (see residency). [1, 11, 13]
Who counts as family?
No definition of a family for family office purposes was found in Irish law or Central Bank guidance. The MiFID Regulations 2017 exclude investment services provided exclusively for the provider's parent undertakings, subsidiaries or other subsidiaries of its parent undertakings (Regulation 4(1)(b)); this exemption names only these undertakings and does not mention individuals or family members. Separately, Regulation 4(1)(n) excludes a trustee acting as trustee of a trust, unless the principal objective of the trust is to provide investment services to members of the public. No exemption for services to family members as individual clients was found. [1, 2, 11]
Can one office serve several families?
There is no family office category: an office whose regular business is managing clients' portfolios of financial instruments with discretion or giving investment advice to third parties needs authorisation from the Central Bank as a MiFID investment firm (Regulations 3(1) and 5(1)). The Central Bank's 2021 guidance requires a head office, defined by the location of the firm's mind and management, in Ireland, at least two directors including at least one independent non-executive director, pre-approval of the holders of pre-approval controlled functions (PCFs), and initial capital of EUR 75,000 for a firm that carries on portfolio management or advice without holding client assets (EUR 150,000 if it holds client assets). [1, 2, 11]
Law, substance and vehicles
Which law and courts apply?
Ireland is 'a common law jurisdiction', according to the Law Reform Commission (2017), and its statute law (Acts of the Oireachtas and statutory instruments) is published in the Irish Statute Book; succession is governed by the Succession Act 1965. Investment firms are authorised and supervised by the Central Bank of Ireland under the European Union (Markets in Financial Instruments) Regulations 2017, and income, capital gains, corporation and gift and inheritance taxes are national taxes administered by the Revenue Commissioners. [1, 2, 14, 15, 16]
What substance is required?
No office, staff or spending rule for a single family office was found. An authorised MiFID investment firm, such as a multi-family office, must have its head office (the location of its mind and management) in Ireland and 'a significant senior management presence in Ireland', with board decisions and the financial control, legal and compliance and risk functions in Ireland, according to the Central Bank's guidance. [1, 11]
Which holding vehicles are available?
Families can hold investments through Irish companies (close companies pay a surcharge on undistributed investment income, see family office tax), through trusts, and through Irish-domiciled investment funds. Discretionary trusts pay a once-off discretionary trust tax of 6% (3% if the property is transferred out absolutely within five years) and an annual 1% on 31 December under the Capital Acquisitions Tax Consolidation Act 2003, according to Revenue's CAT manual; exemptions from these charges were not checked. Partnerships, the ICAV and other fund vehicles were not checked in official sources. [4, 17, 18]
Tax
What is the corporate tax rate?
Corporation tax is 12.5% on trading income and 25% on non-trading income taxed under Schedule D Cases III, IV and V, such as interest, royalties and rental income, and on excepted trades such as dealing in or developing land; companies' chargeable gains are computed under capital gains tax rules and charged to corporation tax at 33% (Revenue manual reviewed January 2024, before Budget 2027 announced a 31% capital gains tax rate; whether companies' gains follow that cut was not checked). Groups with consolidated revenue of at least EUR 750 million in at least two of the four preceding fiscal years pay a minimum effective rate of 15% under Pillar Two (income inclusion rule and domestic top-up tax for fiscal years from 31 December 2023, undertaxed profits rule from 31 December 2024). A family holding company receiving foreign dividends can elect the participation exemption for distributions made on or after 1 January 2025 from a company resident in an EEA or tax treaty country (or, from 2026, a specified territory) in which it has held at least 5% for 12 months. [3, 19, 20, 21]
Are there tax incentives for family offices?
No tax regime for family offices or family investment companies was found. A family investment company pays 25% on non-trading income and, as a close company, a 20% surcharge on undistributed estate and investment income (rent, interest and dividends), reduced if the income is distributed within 18 months of the end of the accounting period and not charged where the undistributed excess is EUR 2,000 or less. CAT business relief does not apply to a business that consists wholly or mainly of dealing in shares, land or buildings or of making or holding investments; individuals' income and gains from Irish investment funds are taxed at 38% exit tax from 1 January 2026 (41% before), and the Finance (No.2) Bill 2026, not yet enacted, cuts it to 35%. [3, 4, 7, 18, 22]
Is there personal income tax?
Residents pay income tax at 20% and 40% (in 2026 the 20% band is EUR 44,000 for a single person; the Finance (No.2) Bill 2026, not yet enacted, raises it to EUR 46,500), plus Universal Social Charge (top rate 8% above EUR 70,044 in 2026) and PRSI, which rose from 4.2% to 4.35% for employees (Class A) and the self-employed (Class S) on 1 October 2026; adding the three top rates gives 52.35% on employment income (our calculation, not an official figure). Capital gains tax is 33%; the Department of Finance says Budget 2027 reduces the standard rate to 31% 'effective from 7 October 2026', but the change is in the Finance (No.2) Bill 2026, published on 19 October 2026 and not yet enacted. Individuals' income and gains from Irish investment funds are taxed at 38% exit tax, and the same Bill cuts it to 35% (no start date in the Department's press release). Residents who are not domiciled in Ireland are taxed on foreign income from securities and possessions, such as foreign investment income, only to the extent it is remitted to Ireland (Irish income, and employment income for duties performed in Ireland, are taxed in full); Irish-domiciled individuals with worldwide income over EUR 1 million, Irish property worth over EUR 5 million on 31 December and an Irish income tax liability below EUR 200,000 pay a domicile levy of EUR 200,000 a year, less Irish income tax paid. The Special Assignee Relief Programme, open to employees assigned to Ireland by their employer who arrive by 2030, exempts from income tax (not USC) 30% of employment income between EUR 125,000 (arrivals from 2026) and EUR 1 million for up to five years. [7, 9, 10, 18, 23, 24, 25, 26, 27]
Is there inheritance or estate tax?
Capital acquisitions tax (gift and inheritance tax) is charged at 33% on gifts and inheritances above lifetime group thresholds, counted since 5 December 1991. Budget 2027 announced higher thresholds for gifts and inheritances taken on or after 7 October 2026: EUR 420,000 for Group A (mainly a child or stepchild of the disponer), EUR 44,000 for Group B (for example grandchildren, siblings, nephews and nieces) and EUR 22,000 for Group C (everyone else), up from EUR 400,000, EUR 40,000 and EUR 20,000 (from 2 October 2024 to 6 October 2026). The increase is in the Finance (No.2) Bill 2026, not yet enacted; Revenue's thresholds table already lists the new figures 'On or after 7 October 2026', and its eBrief 149/26 describes them as 'announced in Budget 2027'. Gifts and inheritances from a spouse or civil partner are exempt, the first EUR 3,000 of gifts from any one person in a calendar year is exempt (not inheritances), and business relief and agricultural relief reduce the taxable value by 90%. All property in Ireland is within the charge, and foreign property when the disponer or the beneficiary is resident or ordinarily resident in Ireland (special rules for people not domiciled in Ireland were not checked); discretionary trusts pay a once-off 6% and an annual 1% discretionary trust tax. [5, 6, 7, 16, 17, 22, 28, 29, 30, 31]
Succession and residence
How do wills and succession work?
A surviving spouse or civil partner has a legal right share of one half of the estate if there are no children and one third if there are children, regardless of the terms of the will (sections 111 and 111A of the Succession Act 1965). Where a parent dies leaving a will, a child can ask the court for provision if the parent 'failed in his moral duty to make proper provision for the child' in accordance with his means (section 117); the application must be made within six months of the first taking out of representation (reduced from twelve months in 1996, per the Law Reform Commission), and an order cannot affect the spouse's legal right share. On intestacy a spouse with children takes two thirds and the children one third. [14, 15, 32, 33, 34]
Can the family get residence?
The Immigrant Investor Programme closed to new applications at close of business on 15 February 2023 (applications on hand continue to be considered). Non-EEA people who want to retire to or live in Ireland as persons of independent means apply before arrival for Stamp 0 permission: Immigration Service Delivery says applicants should have an individual income of EUR 50,000 a year, with access to a lump sum to cover sudden major expenses (for example the price of a home in Ireland) and private medical insurance; 'investment sums are not normally measured', as finances must be pension income or readily accessible funds. Stamp 0 holders must not work or engage in any business, trade or profession unless their letter of permission allows it, and cannot use State benefits; the pages opened describe renewal but do not say how long the permission lasts or whether family members can join. The Start-up Entrepreneur Programme gives two years' residence, renewable for three, to founders of an innovative high-potential start-up with at least EUR 50,000 in funding and the potential to create 10 jobs and EUR 1 million in sales; a spouse or partner and children under 18 can accompany, and long-term residence may follow after five years. [8, 13, 35, 36, 37]
Time and fees
How long does set-up take?
No official time to register a company was found in the sources opened. For an office that needs MiFID authorisation (such as a multi-family office), the Central Bank's guidance says a determination will be made within 6 months of receipt of a complete application. [11]
What are the official fees?
Not found in official sources: the Companies Registration Office fee schedule could not be opened within the research limits, and no Central Bank authorisation fee was found in the pages opened. No family office licence fee exists because no family office licence was found.
Pros and cons
Pros
- No wealth minimum, and an office that provides investment services only to its parent, subsidiaries or sister companies falls outside the MiFID Regulations 2017.
- Residents who are not domiciled in Ireland are taxed on foreign investment income only to the extent it is remitted, and foreign dividends to a holding company can be exempt under the participation exemption (at least 5% held for 12 months).
- Gifts and inheritances from a spouse or civil partner are exempt, a child can receive up to EUR 420,000 in total from parents without tax for gifts and inheritances from 7 October 2026 (Budget 2027 threshold, listed by Revenue but still in a Bill; EUR 400,000 before), and business and agricultural relief cut the taxable value by 90%.
Cons
- No exemption for services to individual family members was found in the MiFID Regulations 2017, which require authorisation for any regular business of providing investment services, such as portfolio management, to third parties.
- Top rates of 40% income tax, 8% USC and 4.35% PRSI add up to 52.35% on employment income (our calculation), and a family investment company pays 25% on non-trading income plus a 20% surcharge on undistributed investment income.
- The Immigrant Investor Programme closed in February 2023; non-EEA people of independent means need Stamp 0 (EUR 50,000 individual income a year) and may not work or run a business unless their permission allows it.
