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5 Mistakes US Founders Make Relocating to Dublin (and How to Avoid Them)

The overlaps between US and Irish tax, entity structure and hiring create predictable, expensive traps. Here are the ones we see most often.

By Viki8 min read
Editorial illustration of a Georgian Dublin doorway alongside a founder's desk, representing a US-to-Ireland founder move.

Founder relocations look like personal moves with a company attached. They're not. The company decisions — where the IP lives, who employs whom, when substance is established — determine what the founder can and can't do on the personal side.

Every mistake below is one we've watched a smart, well-advised US founder make. None of them are obvious in advance. All of them are expensive to unwind.

1. Setting up the Irish entity before the visa route is confirmed

Founders often incorporate an Irish limited company the week they decide to move, thinking it's the fast, tangible step. It usually isn't the right first step.

The visa route dictates the entity structure, not the other way around. A Critical Skills employment permit requires an Irish employer — but if that employer is your own newly-formed company with no revenue, the permit is much harder to grant. The Start-up Entrepreneur Programme (STEP) requires innovation criteria, funding evidence, and an approved business plan reviewed by Enterprise Ireland. A business permission route needs €300,000 of capital committed and evidence of two jobs created.

Choose the route first. Then form the entity that supports it. The reverse order costs six to nine months.

2. Underestimating personal Irish tax residency

The Irish residency rules are precise: 183 days in a tax year, or 280 days across the current and prior tax year. Miss the count by a week and your worldwide income becomes Irish-taxable a year earlier than you planned.

The subtler issue is domicile. Non-domiciled residents are taxed on the remittance basis — foreign income and gains are only taxed when brought into Ireland. This is a genuine advantage for US founders holding company shares, but only if it's structured correctly before residency starts. Remittance planning after arrival is remedial and expensive.

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3. Hiring in Ireland before payroll and PRSI are set up

Founders sometimes hire their first Irish employee before the Irish payroll, PRSI (social insurance), and pension auto-enrollment obligations are in place. Ireland's Revenue Online Service (ROS) doesn't forgive late registration lightly, and once you've paid someone without payroll running, back-filing is manual and painful.

The clean sequence is: entity formed, tax registrations complete (Corporation Tax, PAYE/PRSI, VAT if applicable), payroll provider onboarded, then first hire. Two months of runway between entity formation and first payslip is normal.

4. Opening the personal bank account before the PPSN

Every Irish bank now requires a PPSN (Personal Public Service Number) for account opening. Founders who try to open a bank account before their PPSN comes through end up either delayed by three to six weeks, or with a Revolut / Wise account that isn't accepted by their Irish landlord as proof of banking.

The correct order is: address then PPSN appointment then Irish bank account then Revenue registration then everything else. Skipping steps triggers rework, not shortcuts.

5. Assuming US IP can just move to Ireland

Ireland's 12.5% corporate rate and Knowledge Development Box are real, but IP migration from a US Delaware C-corp to an Irish entity is a taxable event on the US side. The transfer needs a valuation, an §367 or §482 analysis, and often a step transaction plan that spans a US tax year.

Founders who want the Irish tax treatment on new IP should form the Irish entity early, develop new IP there from day one, and license existing US IP in — rather than trying to sell or contribute existing US-owned IP into Ireland after the fact. This is a decision that has to be made before Irish substance is established, not after.

These aren't obscure edge cases — they're the five things we see repeatedly, in that order. A Discovery Call is a 30-minute walk-through of which of them apply to your specific setup and what the correct sequence looks like.

Frequently asked

Can I move to Ireland as a US founder without setting up an Irish company?

Yes — if your income continues from the US company and you're on a personal visa route (Stamp 0 for passive income, or Stamp 4 through a spouse). If you want to actively run an Irish operation, hire in Ireland, or use Irish tax treatment, an Irish entity is required.

Is the Start-up Entrepreneur Programme (STEP) worth the effort?

For innovative, funded startups, yes — it's a clear route with a 24-month initial permission and a path to Stamp 4. It requires €50,000 of funding, a business plan reviewed by Enterprise Ireland, and evidence of innovation. Timeline is typically 4–6 months from application to decision.

How does Irish corporate tax compare to US for a small startup?

Ireland's 12.5% trading rate is materially lower than US federal plus state combined. But the total picture depends on where IP lives, whether you're paying yourself PAYE or dividends, and how US shareholders are treated. Get an Irish tax advisor and a US CPA aligned before you incorporate anything.

Do I need to be in Ireland to run an Irish company?

At least one director must be resident in the European Economic Area (EEA), or the company must post a €25,000 non-resident director bond. If you're the sole director and relocating, you become the EEA-resident director on arrival — which means your entity formation should be timed to your landing, not the month you decide to move.

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