Written answers

Wednesday, 12 November 2014

Department of Finance

Universal Social Charge Exemptions

Photo of Dominic HanniganDominic Hannigan (Meath East, Labour)
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55. To ask the Minister for Finance if artists who earn an income from the sale of their creative work and who are resident outside the State are liable to pay USC on their earnings from the sale of their products in this state; and if he will make a statement on the matter. [43373/14]

Photo of Michael NoonanMichael Noonan (Limerick City, Fine Gael)
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As a general rule, a non-resident individual who carries on a trade or profession in the State is liable to income tax and universal social charge (USC) on the profits therefrom.

However, if the individual is resident in a state with which Ireland has a double taxation treaty, the profits are only liable to Irish income tax and USC if the trade or profession is carried on through a permanent establishment in Ireland. This rule applies to profits from sales by a non-resident artist also.  In practice, it is likely that very few foreign resident artists would trade in Ireland through a permanent establishment, with the result that few foreign artists, if resident in a treaty state, would have a liability to Irish income tax and USC.

Currently, the artists' exemption only applies to individuals who are resident in Ireland and are not resident elsewhere.  It is proposed in the current Finance Bill to extend artists' exemption to individuals resident in other Member States of the EU or in European Economic Area (EEA) States.  However, this exemption only applies in respect of income tax and not USC.Therefore, if the proposal in the Finance Bill is passed, there will be no change to the position as set out above.  

Further information on the USC is available from the Revenue website at:

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