TLC is a multinational company that specializes in consumer electronics. The company has multiple offices throughout Europe and the USA, with the European headquarters based in Germany. The company recently established an Irish company (TLC IE) in Dublin and is also considering opening an office in Cork. You have recently been recruited as an employment tax manager and you are required to provide payroll, tax, USC, PRSI advice on the following matters:
- Burnard Muller a Geman national, has been engaged as a non-executive director of TLC IE. He is required to attend quarterly board meetings in Dublin which he will travel to directly from his home in Germany. Burnard will receive a director’s fee of €20,000 in addition to the reimbursement of the expense he incurs in attending the board meetings in Ireland. This is his only income from Ireland and the board meetings will be Burnard’s only trips to Ireland this year. Burnard is married to Heidi who owns a dental practice in Germany.
- Pamela Farrell a UK national, was employed in the company’s UK office, TLC UK for the past 4 years. She requested a permanent transfer to the Dublin office as her fiancé Cian lives in Ireland and she wishes to relocate to Ireland. Pamela will transfer and take up employment with TLC IE on the 1st of May 2023. She will receive an annual salary of €30,000. Pamela is getting married in September. Pamela is excited about her upcoming wedding and is looking forward to living outside of the UK for the first time. Cian is employed in Ireland and has taxable income of €46,000 a year. Pamela has asked for advice as to how all of this will impact on her tax, PRSI and USC for this year.
- Bradley Morris a US national will be temporarily assigned to TLC IE from the US company ( TLC US) on 1st of June 2023 on a 2 year assignment and he will return to his current role in TLC USA at the end of May 2025. He has been working for TLC USA for 12 years. Bradley is paid a salary of €220,000 per year. He will contribute €20,000a year into a qualifying overseas USA pension scheme. He will be provided with company car in Ireland which has a national value of €21,600 per year. Bradley’s wife and children will remain in the USA for the duration of his stay, but TLC USA has agreed to pay for the cost of 6 return flights per year. Each return flight will cost €1,500. 2 of these flights will occur in 2023to coincide with 2 periods of annual leave totalling 18 days. TLC USA has agreed to pay €27,000 per year in respect of rental accommodation for Bradley in Ireland. Bradley is looking forward to his assignment as it will be his first time in Ireland. TLC does not operate a tax equalisation agreement. Bradley will continue to be paid by TLC USA and TLC IE will account for any payroll taxes due in Ireland