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Tuesday, 11 Jun 2024

Written Answers Nos. 184-203

Revenue Commissioners

Questions (184)

Róisín Shortall

Question:

184. Deputy Róisín Shortall asked the Minister for Finance to respond to matters raised in correspondence (details supplied); if arrangements can be made to facilitate general practices operated by registered charities, given the immediate implications of not finding a resolution; if he will urgently engage with the Revenue Commissioners in respect of this matter; and if he will make a statement on the matter. [25052/24]

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Written answers

My Department and Revenue have, for some time, been aware of issues which arose from contractual arrangements within the General Practitioner (GP) community whereby some GPs treat income under their General Medical Services (GMS) contract as income of a GP practice in which they are a partner or an employee, rather than income of that individual GP.

To clarify the correct tax treatment of GMS income under tax legislation, Revenue issued a guidance note to tax practitioners through the Tax Administration Liaison Committee in July 2023. That guidance confirmed there would be a transitional period until 31 December 2023 for compliance with existing tax law. That period has not been extended. Revenue published supplementary guidance on this matter on 10 November 2023, which is available at the following link: www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-04/04-01-15.pdf

Although the guidance was widely reported as a tax change, it did not, in fact, introduce a change to the tax treatment of GPs. Instead, it simply clarified the existing legal and administrative position.

In accordance with Section 58 of the Health Act 1970, a GMS contract is between the HSE and an individual GP. This means that, as a matter of law, income under a GMS contract belongs to the GP who entered into the contract with the HSE. The position does not change because a GP treats their GMS income as income of a medical practice.     

Following on from that fact, under the legislation, there is no legal basis for Revenue to treat income arising under a GMS contract entered into between an individual GP and the HSE as if it were income arising under a contract between the HSE and the medical practice in which the GP is a partner or an employee.

A GP who holds a GMS contract is, under tax legislation, a chargeable person as regards income arising under the GMS contract and should report that income under the self-assessment system. The GP is also the specified person for the purposes of Professional Services Withholding Tax (PSWT), which means they are entitled to claim a credit for PSWT deducted by the HSE on GMS payments.

However, as part of Finance (No. 2) Act 2023, I introduced Section 1008A of the Taxes Consolidation Act 1997. This new section provides that, where individual GPs enter into contracts with the HSE to provide certain medical services and provide those services in the conduct of a partnership profession with other individual GPs, the income from those services can be treated for income tax purposes, to be that of the partnership, where a joint election is made. 

Section 1008A TCA 1997 has been effective since 1 January 2024. However, it only applies in the case of individual doctors who operate in partnerships with other individual doctors. It does not apply to, or change, the tax situation for doctors who are employees of a corporation or other arrangement, such as the GPCareForAll model. It is also limited only to income arising from GMS and certain ancillary medical services income.

The core issue concerns the contractual arrangements involving GPs. It should be noted that because there are a number of business arrangements and models in the GP sector, including partnerships, companies, employees and employers, it would not be appropriate for tax legislation to seek to accommodate all contracts and business practices in the sector. As such, the Minister for Health has confirmed that the Strategic Review of General Practice, which is underway, will examine the relevant HSE contracts and propose measures necessary to modernise them.

Departmental Contracts

Questions (185)

Catherine Murphy

Question:

185. Deputy Catherine Murphy asked the Minister for Finance the number of contracts awarded by his Department to a company (details supplied) to carry out work on behalf of his Department in the years of 2023 and to date in 2024, in tabular form. [25109/24]

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Written answers

The ‘National Public Procurement Policy Framework’ issued by the Office of Government Procurement (OGP) sets out the procurement procedures to be followed by government departments and state bodies in accordance with EU rules and national guidelines.

In addition, my Department has its own internal policy and guidance documents to assist staff to comply with all procurement regulations.

I am informed that my Department has not awarded any contracts to the company named by the Deputy in the period 2023 to date.

Fiscal Data

Questions (186)

Rose Conway-Walsh

Question:

186. Deputy Rose Conway-Walsh asked the Minister for Finance to provide details on the reason why the stability programme update is projecting the increase of gross debt in nominal terms despite running a general government surplus; and if he will make a statement on the matter. [25161/24]

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Written answers

The Stability Programme Update (SPU) published by my department in April forecasts an increase in nominal general government gross debt of €11.8 billion between 2023 and 2027. Over the same period, a general government surplus is forecast for each year to the cumulative value of €37.7 billion.

Movements in general government gross debt can be explained by the general government deficit/surplus and the so-called stock-flow adjustment (SFA).

While conceptually a general government surplus should contribute to a reduction in debt levels, this is not always the case; in a symmetric manner, a general government deficit does not necessarily translate into an increase in debt.

This is because changes in general government gross debt also reflect other elements, such as the financing of the acquisition of financial assets, which do not appear in the surplus/deficit figures. These other elements are included in the SFA. 

To put it in practical terms, if the NTMA decides to issue more debt instruments because of favourable financial conditions, for instance, this will increase the debt irrespective of whether there is a budget surplus.  These debt instruments will be used at a future date to finance maturing debt.

A breakdown of the items that contribute to the positive SFA is outlined in Table 17 in the SPU, with the other (2g) category being the largest. This category includes the accumulation of financial assets in the Future Ireland Fund, the Infrastructure, Climate and Nature Fund and the Social Insurance Fund.

Finally, it is important to stress that the accumulation of assets in such funds will contribute to improving the sustainability of the public finances.

Tax Data

Questions (187)

Patrick Costello

Question:

187. Deputy Patrick Costello asked the Minister for Finance for an update on the implementation of each of the recommendations outlined in the 2022 Commission on Taxation and Welfare Report: Foundations for the Future; and if he will make a statement on the matter. [25166/24]

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Written answers

The Commission on Taxation and Welfare (the Commission) was established in April 2021 as a result of a commitment in the Programme for Government. The Commission was asked to independently consider how best the taxation and welfare systems can support economic activity, and promote increased employment and prosperity while ensuring that there are sufficient resources available to meet the costs of the public services and supports in the medium and longer term.

‘Foundations for the Future’, the Report of the Commission on Taxation and Welfare, was published in September 2022. It is a wide ranging report that contains 116 recommendations relating to the future of our taxation and welfare systems.

The Commission’s recommendations are significant and wide ranging. It is clearly set out in the Commission’s report that the recommendations are not intended to be implemented all at once, but rather provide a clear direction of travel for this and future Governments around how the sustainability of the taxation and welfare systems may be improved in a fair and equitable manner.

Notwithstanding this express medium to long term view, since the publication of the report my Department has examined the Commission’s recommendations in detail, in particular those relating to taxation, and has taken a number of actions.

For example, my Department conducted a review of Ireland’s personal tax system which was published with Budget 2024. In addition, as recommended by the Commission, my Department is conducting a wide-ranging review of the funds sector under the broad and interlinked themes of “Open Markets, Resilient Markets and Developing Markets”. A public consultation has been completed and a wide range of research, analysis and stakeholder engagement has been undertaken.

My Department is also currently undertaking a review of share-based remuneration which will include further consideration of recommendations made by the Commission on this topic.

Outside of these reviews, a number of legislative amendments have been made which incorporate some of the recommendations of the Commission. For instance, with regard to taxes on capital and wealth, Finance (No. 2) Act 2023 implemented a recommendation from the Commission to introduce a limit on retirement relief on the disposal of businesses and farms to children up to the age of 66. That Act also amended legislation to ensure foster children can avail of the group B capital acquisitions tax threshold based on their relationship to their foster parents. The Act also.

In relation to supporting enterprise and in particular small and medium enterprises (SMEs), the Finance (No. 2) Act 2023 implemented a number of enhancements to the Employment Investment Incentive (EII). A review of this incentive is currently underway. That Act also provided for a new capital gains tax relief for angel investors.

In line with a recommendation of the Commission, Finance (No. 2) Act 2023 also saw an amendment was made to the taxation of rights to acquire shares options or other assets. This amendment moved the obligation to account for the tax due on these rights from the self-assessment system to the Pay as You Earn (PAYE) system.

The Commission recommended that a Local Property Tax (LPT) surcharge should be introduced for vacant properties. Finance Act 2022 introduced a new Vacant Homes Tax (VHT), charged at a multiple of a property’s base LPT charge. Last year, in Budget 2024, I announced an increase in the rate of VHT from three to five times a property’s base LPT charge. VHT is payable in addition to LPT on properties which are occupied for less than 30 days in a 12-month period.Finance Act 2022 also saw the implementation of changes to the Key Employee Engagement Programme (KEEP).

The annual increases in the carbon tax have been implemented to date as legislated for in Finance Act 2020.  The most recent increase occurred for motor fuels in October 2023 and for all other fuels from 1 May 2024. The rate is now €56 per tonne of carbon dioxide. The Government is committed to increasing the amount that is charged per tonne of carbon dioxide emissions from fuels to €100 by the end of this decade as recommended by the Commission. A phased removal of the diesel excise gap as well as other fossil fuel subsidies in the road transport sector was examined in the 2023 Tax Strategy Group Paper on Climate Action and Tax. 

The introduction of an emissions-based tax regime for light goods vehicles (VRT Category B) will be explored in greater detail in the 2024 Tax Strategy Group Paper as part of the policy objective to redesign vehicle taxes in the medium to long term to support environmental objectives and ensure the maintenance of tax revenues.

In relation to the use of taxation in promoting public health, excise duty on tobacco products has increased consistently over the past decade and Budget 2024 provided the highest increase in excise, at a rate of €0.75 on 20 pack cigarettes in the Most Popular Price Category (MPPC). Additionally, I announced in Budget 2024 my intention to introduce a domestic tax on e-cigarette liquids in Budget 2025.

The Department is focused on and committed to improving how tax expenditures are reported. My officials have been working closely with Revenue to implement recommendations from the Commission on Taxation and Welfare Report in this area.

The Department now holds a master list of tax expenditures which is used by the Department for budgetary planning and by Revenue for statistical reporting and transparency purposes.

In addition, the Department has been working on updating their Guidelines for Tax Evaluation, which will include a strategic plan for future tax reviews to cover all tax expenditures. The updated Guidelines on Tax Expenditures will be published over the coming months and will address many of the recommendations of stakeholders.

In Budget 2024 I announced two major new funds to help protect living standards and public services into the future as these funds, the Future Ireland Fund and the Infrastructure, Climate and Nature Fund are in line with the Commission’s recommendation to utilise excess corporation tax receipts.

With regard to roadmaps and feedback statements, a Roadmap for the Introduction of a Participation Exemption to the Irish Corporate Tax System was published in September 2023, and a feedback statement on the development of a participation exemption for foreign dividends was published in April 2024.

Banking Sector

Questions (188)

Patrick Costello

Question:

188. Deputy Patrick Costello asked the Minister for Finance for his view on the potential to introduce a windfall tax on Irish banks given their increasing profit margin; and if he will make a statement on the matter. [25167/24]

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Written answers

As a small open economy, connected to Europe, the US and the wider world, Ireland is committed to a competitive, transparent and stable corporation tax system. As the Deputy will be aware, the trading profits of companies in Ireland are generally taxed at the standard corporation tax rate of 12.5%, and under the Pillar Two agreement the effective rate has increased to 15% for in-scope companies.

Imposing additional taxes on certain sectors would involve increased complexity and could change the attractiveness of Ireland's corporate tax regime. While it is possible that imposing such taxes could lead to theoretical gains, there is a risk of such taxes leading to lower levels of economic activity and to companies passing the additional tax burden onto their suppliers or consumers.

In relation to introducing a windfall tax on banks, there are a number factors would need to be considered, such as the potential for negative impacts on bank customers and employees, and further reduced appetite for competition in a sector that has recently seen the departure of two significant banks.

Introducing a windfall tax could have an impact on the capital position of the banks, and consequently on their market value, resulting in an immediate reduction in value of the State’s remaining shareholdings. It would also have the potential to damage the State’s credibility in the international markets, and this could have negative consequences for values achieved in future share sales.

From a consumer perspective, increased costs and reduced competitiveness in the banks as a result of a windfall tax could potentially lead to pricing increases or reduced services. This could have a negative impact on consumers – for example through increased fees, increased mortgage interest rates, or reduced lending to Irish businesses – or on employment in the Irish banks if cost-cutting measures are required.

The Deputy may be aware that a banking sector specific measure has been in place since 2014, in the form of the bank levy. Finance (No.2) Act 2023 provided for a revised form of the bank levy based on the end-2022 eligible deposits of four named institutions that received State assistance during the banking crisis (AIB, EBS, PTSB, and Bank of Ireland).  The 2024 target revenue of €200 million stipulated in Finance (No.2) Act 2023 is more than twice the €87 million raised in 2022 and 2023 by the previous form of the levy, and one third more than the circa €150 million raised under it each year between 2014 and 2021.

The operation, extent and target revenue of the bank levy will be further considered in advance of Budget 2025.

Primary Medical Certificates

Questions (189)

Richard Bruton

Question:

189. Deputy Richard Bruton asked the Minister for Finance if he has set a deadline for when the final proposals on the review of the primary medical certificate for motor and fuel tax concessions will be brought to Government; and if he will make a statement on the matter. [25272/24]

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Written answers

The Deputy should note that  my Department and I share concerns that the Disabled Drivers and Disabled Passengers Scheme (DDS) is no longer fit-for-purpose and believe it should be replaced with a needs-based, grant-led approach for necessary vehicle adaptations that could serve to improve the functional mobility of the individual.

However, this is very much a matter for Government as whilst my Department has oversight of the DDS, I do not have responsibility for disability policy.

In that context, any further changes to the existing DDS would run counter to the National Disability & Inclusion Strategy (NDIS)  proposals to entirely replace the scheme with a modern, fit-for-purpose vehicular adaptation scheme.

Under the aegis of the Department of Taoiseach officials from relevant Departments and agencies are meeting to discuss the issues arising from the NDIS report and to map a way forward. One of these issues which is being examined is how the DDS can be replaced. Four meetings of the group have been held, in July, November, December 2023; and March 2024.  

The Department of Finance submitted a note to the group with my approval in mid-January 2024. This note outlines a proposal for a replacement scheme for the DDS which would be a needs-based, grant-led approach for necessary vehicle adaptations that could serve to improve the functional mobility of the individual. This proposal is in line with what the NDIS Transport Working Group Report endorsed. Further consideration is being given to the principles and parameters for a new scheme in line with best international practice.

Overseas Development Aid

Questions (190)

Rose Conway-Walsh

Question:

190. Deputy Rose Conway-Walsh asked the Minister for Finance to outline the level of both voted and non-voted overseas development aid contained within the SPU projections; and if he will make a statement on the matter. [25280/24]

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Written answers

As the Deputy may be aware, the Stability Programme Update sets out on a technical, no policy change basis, Ireland’s budgetary projections, including voted expenditure projections, over the forecast horizon (from 2023 to 2027) on an aggregate level.

On this basis, the voted expenditure ceilings reflect the 5% growth rate set out in Government's medium-term budgetary strategy. SPU ceilings for voted expenditure are set at an overall level, reflecting the total voted funding to be provided across Departments each year. Funding is allocated as part of the annual estimates process. For 2024, I am advised that the Department of Foreign Affairs’ development assistance budget is €776.5 million, with Official Development Assistance from across all of Government standing at €2 billion.

The SPU also sets out projections for non-voted current and non-voted capital expenditure on an aggregate basis, and I am advised by my officials that a limited number of these payments will constitute ‘overseas development aid’.  Last year, non-voted expenditure relating to overseas development aid totalled approximately €110 million.

Revenue Commissioners

Questions (191)

Michael Lowry

Question:

191. Deputy Michael Lowry asked the Minister for Finance his response to concerns from a company (details supplied) that were refused a refund on VAT items that previously qualified; when an updated guidance document will issue on all outstanding information and VAT claims received by the Revenue Commissioners; will the Revenue Commission now process a VAT refund for the attached claim; and if he will make a statement on the matter. [25282/24]

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Written answers

The VAT treatment of goods and services is subject to EU VAT law, with which Irish VAT law must comply.  In accordance with the EU VAT Directive, farmers can elect whether or not to register for VAT in respect of their farming business, and this affects how VAT incurred on their inputs (such as the purchase of farm equipment) is treated.

Farmers who elect to register for VAT are obliged to account for VAT on their supplies and are entitled to claim a deduction for VAT incurred on inputs used for the purposes of their taxable supplies.  Therefore, VAT-registered farmers would be entitled to reclaim the VAT incurred on farm equipment, including bulk milk tanks, and this should be done through their normal VAT returns.

Alternatively, farmers can remain unregistered for VAT and opt for the Flat-Rate Farmer’s Scheme. This scheme is a simplification arrangement permitted under the Directive.  It is designed to reduce the administrative burden for farmers by allowing unregistered farmers to be compensated on an overall basis for VAT on inputs, while remaining outside the VAT system, thereby avoiding the burdens associated with registration and filing.  It allows such farmers to add a percentage charge (known as the “flat-rate addition”) onto the amount they invoice VAT-registered businesses whom they supply with agricultural goods and services in the course of their farming business.  Unlike VAT-registered businesses, unregistered farmers are not entitled to a deduction for VAT incurred on individual inputs used in their farming business; instead, the Flat-rate Scheme permits them to charge and retain the flat-rate addition in order to compensate them, on an overall basis, for the VAT across all their inputs.

There are certain limited situations in which flat-rate farmers are specifically permitted to claim a refund of the VAT incurred by them on particular inputs.  The Value-Added Tax (Refund of Tax) (Flat-rate Farmers) Order 2012 (S.I. No. 201/2012) allows for refunds to be claimed on outlay incurred on:

-          the construction, extension, alteration or reconstruction of a farm buildings or structures.

-          the fencing, draining and reclamation of farmland; and

-          the construction and/or installation of qualifying equipment for the purpose of micro-generation of electricity for use in a farm business.

Outlay incurred by flat-rate farmers on the acquisition of farm equipment does not come within the scope of the refund order. However, where the installation of the equipment requires the alteration or reconstruction of a farm building or structure, the corresponding expenditure on the alteration or reconstruction of the building or structure including equipment or elements of equipment permanently installed in the farm building or structure may be allowed in certain circumstances. The equipment must be permanently installed in the farm building or structure and, once installed, cannot be removed without causing significant damage or destruction to the farm building or structure or to the equipment itself.

The claim in question (details supplied) refers solely to outlay on the purchase of a replacement milk tank, with no evidence of works undertaken to alter or reconstruct the building. Consequently, the claim was refused on the basis that the outlay being claimed does not come within the scope of the Refund Order. Claims that do not comply with the Order cannot qualify for a refund. Claimants are encouraged to provide supporting documentation, photos and detailed descriptions of the works carried out to the building or structure to allow for the instalment of equipment.

Where the claimant has evidence of works to alter or reconstruct the building, Revenue can review the claim, following resubmission with the necessary documentary evidence of the works undertaken to the building or structure to establish the extent to which the equipment is integral to the building, and the level of damage that would be caused to the building or the equipment should it be removed.

Revenue published a Tax and Duty Manual (TDM) on 4 June 2024 to provide guidance on the Refund Order.  The TDM outlines how VAT can be reclaimed under the Order by flat-rate farmers, the conditions under which VAT may be reclaimed, the types of expenditure on which VAT can be reclaimed, and the information required to make a claim.

Tax Exemptions

Questions (192)

Michael Lowry

Question:

192. Deputy Michael Lowry asked the Minister for Finance if he will consider raising the tax exemption for persons of pension age to account for inflation and the rising cost of living (details supplied); and if he will make a statement on the matter. [25283/24]

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Written answers

As the Deputy is aware, the age exemption applies for any year of assessment where an individual is aged 65 years or over and his or her total income does not exceed €18,000 per annum. Where an individual is a married person or civil partner and is jointly assessed to tax, the age exemption will apply where either individual is aged 65 or over and where the couple’s total income does not exceed €36,000 per annum. The relevant income thresholds may be increased further if the individual has a qualifying child. The thresholds are increased by €575 in respect of both the first and second child, and €830 in respect of each subsequent child.

It is important to note that marginal relief may be available where the individual’s or couple’s income exceeds the relevant exemption limit but is less than twice that amount. Where marginal relief applies the individual or couple is taxed at 40 per cent on all income above the exemption limit to a ceiling of twice the exemption limit. The system of marginal relief ensures that in cases where an individual's or couple’s income rises above the exemption threshold that their net income will not decline, as the 40 per cent income tax rate only applies to the proportion of income above the threshold. Once the income exceeds twice the exemption limit marginal relief is no longer available and the individual pays tax under the normal tax system.

It should be noted, however, that where the individual’s income is greater than the exemption limit but below twice that limit, the taxpayer is entitled to the benefit of the more favourable treatment between the use of marginal relief or the normal tax system of credits and bands.

I have no plans to increase the age exemption limits. However, it should be noted that in circumstances where the individual or couple no longer benefits from the age exemption or marginal relief they will benefit from the increases to the main personal tax credits in recent Budgets.

The increases to the main personal tax credits in Budget 2024 (€100 increase to the single, employee and earned income credits and a €200 increase to the credit for married couples/civil partnerships) means that the effective entry point to income tax has increased for all taxpayers, including those aged over 65. From 2024, the effective entry point to income tax for an individual in receipt of the single person credit, employee/earned income credit and the age credit has increased by €1,000 per annum from €18,975 to €19,975 per annum.

It is important to take into account that the current tax arrangements for persons aged 65 or older compare favourably with the tax treatment of the generality of taxpayers. Persons aged 65 or over may also avail of the age tax credit, which currently amounts to €245 per year for single persons or €490 per year for married couples or civil partners. Reduced rates of USC also apply for persons aged 70 or older where their total income is €60,000 or less per annum. Social welfare income such as the State Contributory Pension and State Non-Contributory Pension are excluded from the calculation when determining if an individual’s income has exceeded the €60,000 income threshold. Furthermore, the State Contributory Pension and the State Non-Contributory Pension are not chargeable to USC or Pay Related Social Insurance.

The Commission on Taxation and Welfare recommended that age should be removed as a factor for determining the charge to income tax and USC. The report stated that the determination of an individual’s tax treatment based on age narrows the base and breaches the concept of horizontal equity, whereby those with similar income should pay the same proportion of that income in taxes. It also breaches the concept of intergenerational equity. Further details are set out in the Report of the Commission, at the following link - www.gov.ie/en/publication/7fbeb-report-of-the-commission/. 

Finally, as part of the Personal Tax Review published on Budget Day, my Department set out further analysis of the recommendations of the Commission on Taxation and Welfare, including in respect of the age exemption limits. The Report is available at the following link - www.gov.ie/pdf/?file=https://assets.gov.ie/273335/96f70eb1-64e1-4f02-9096-e36f306a048b.pdf#page=null. 

Revenue Commissioners

Questions (193)

Louise O'Reilly

Question:

193. Deputy Louise O'Reilly asked the Minister for Finance further to Parliamentary Question Nos. 237 of 14 May 2024 and 220 of 21 May 2024, how many companies had failed to engage with the Revenue Commissioners as of 31 May 2024 to date under the debt warehousing scheme; the total tax debt owed by this cohort; the breakdown of this information, by division and by NACE economic sector, in tabular form; and if he will make a statement on the matter. [25295/24]

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Written answers

As the Deputy is aware, the Tax Debt Warehousing Scheme was introduced in May 2020 to provide a vital liquidity support to businesses impacted by Covid-19 trading restrictions. The scheme allowed businesses to temporarily ‘park’ eligible taxes on an interest-free basis, the vast majority of which related to VAT and payroll taxes deducted by employers from their employees.  Businesses had until 1 May 2024 to put a plan in place to address their warehoused debt. Revenue is firmly committed to supporting viable businesses and has taken a flexible and pragmatic approach to the payment of warehoused debt. The scheme has now ended. 

On 5 June 2024, Revenue published a detailed statistical report on the Debt Warehousing Scheme which demonstrates the significant level of engagement with Revenue in the weeks leading up to the 1 May 2024 deadline.  The report contains details on the 12,747 Phased Payment Arrangements (PPAs) agreed for €1.2 billion of warehouse debt, in addition to analysis of the 7,042 taxpayers who have been removed from the warehouse.   

A breakdown of the 7,042 taxpayers by Division and by Sector is set out in the tables below. This debt is now subject to normal collection and enforcement proceedings, and is subject to interest at the standard rate of 8% or 10% as appropriate.

Division

Taxpayer Count

Total Balance

Business

6,637

€89,933,918

Personal

299

€2,263,300

Medium Enterprises, Large Corporates and High Wealth Individuals

106

€8,397,098

Total

7,042

€100,594,316

Sector

Taxpayer Count

%

Tax Debt (€m)

%

Construction

1,179

17%

18.86

19%

Wholesale and Retail Trade

1,084

15%

16.06

16%

Accommodation and Food

762

11%

13.43

13%

Professional, Scientific, and Technical

681

10%

11.25

11%

Manufacturing

408

6%

6.19

6%

Administrative and Support Service

322

5%

4.14

4%

Transportation and Storage

319

5%

5.02

5%

Agriculture, Forestry, and Fishing

280

4%

3.25

3%

Human health and Social Work

279

4%

2.02

2%

Information and Communication

264

4%

6.88

7%

Real Estate Activities

244

3%

2.27

2%

Education

214

3%

1.71

2%

Arts, Entertainment, and Recreation

182

3%

1.87

2%

Financial and Insurance

67

1%

1.54

2%

All other sectors

757

11%

6.11

6%

Total

7,042

100%

100.59

100%

The statistical report is available from the Revenue website here:

www.revenue.ie/en/corporate/documents/statistics/registrations/covid-19-support-schemes/2024/warehouse-debt-statistics-030624.pdf.

Tax Code

Questions (194)

Pearse Doherty

Question:

194. Deputy Pearse Doherty asked the Minister for Finance the projected revenue raised from legislated increases in the carbon tax in each year from 2025 to 2030 relative to the rate of €56 per tonne in 2024, for example, the revenue raised from the new rate of carbon tax in 2026 relative to a rate of €56 per tonne. [25313/24]

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Written answers

I am advised by Revenue that its Ready Reckoner is available for calculating the annual impact of potential changes in rates of taxation. The Ready Reckoner estimates assume no behavioural change as a result of the additional price increases.  This data is available on the Revenue website at: www.revenue.ie/en/corporate/information-about-revenue/statistics/ready-reckoner/index.aspx.

With regard to multiannual projections, as the Deputy will be aware in July 2023 my Department published a paper examining the Potential Fiscal Impacts of the Transition to a Lower Carbon Economy in Ireland.  The paper examined the potential fiscal impacts of current domestic climate action policies including commitments in the Climate Action Plan 2023 and the Programme for Government and is available online : www.gov.ie/en/publication/dd671-potential-fiscal-impacts-of-the-transition-to-a-lower-carbon-economy-in-ireland/.

The analysis provides an overview of the potential exchequer revenue which may be impacted either negatively or positively by current domestic climate action policies. The paper builds on previous work on green budgeting published in 2022 and uses a scenario analysis of policy measures on exchequer revenues between 2023 and 2030.

It should be noted that this analysis is a point in time exercise and forecasted revenue is estimated using forward projected estimates of energy use from the Environmental Protection Agency (EPA) and Sustainable Energy Authority of Ireland (SEAI).  As previously indicated to the Deputy, projected energy use data is currently being updated and it is anticipated that updated data relating to energy use and tax will be available in the coming weeks. On this basis the Department aims to have updated carbon tax projections and analysis available shortly thereafter.

Departmental Programmes

Questions (195)

Jennifer Whitmore

Question:

195. Deputy Jennifer Whitmore asked the Minister for Finance to provide details of the ISIF funding for the Greystones media campus; what safeguards were put in place to ensure that the development progressed in line with commitments; what conditions were placed on the allocation of these funds; if he has had contact with the developers in relation to the delays in construction; and if he will make a statement on the matter. [25336/24]

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Written answers

The NTMA has informed me that the Ireland Strategic Investment Fund (“ISIF”) carefully evaluated for a number of years ways in which it could invest on a commercial basis to support the development of new film studio infrastructure in Ireland in light of the increasing demand for film studio infrastructure globally, Ireland’s attractiveness as a location for producing content and the potential benefits to the Irish economy.

As a result of those evaluations, ISIF invested in Greystones Media Campus Limited (“GMC”), the company formed to develop a film studio in Greystones. The proposed development by GMC in Greystones secured planning permission in January 2021. In April 2022, it was announced that Hackman Capital Partners (“Hackman”), ISIF and Capwell (a Sisk family investment vehicle) would partner to develop the proposed film studio in Greystones. Hackman is a Los Angeles based real estate investment and operating company which owns and operates film studios in multiple jurisdictions worldwide. Hackman is the majority, controlling shareholder in GMC and ISIF and Capwell are minority, non-controlling shareholders. As part of the transaction, ISIF committed to invest up to €24m of equity in GMC to part fund the acquisition of the site and the development of a film studio campus. The majority of the transaction equity was committed by the other shareholders in GMC.

As the ISIF is a commercial investor it is not able to provide any non-public or commercially sensitive information related to its investment in the company or any particulars of any legal conditions or safeguards contained in the transaction documents.

GMC commenced preliminary works on the site in 2022. However, the film and TV production sector globally faced significant challenges over the last two years which negatively impacted new film studio development projects worldwide (including in Ireland generally and in Greystones).

ISIF has informed me that current status of the development is commercially sensitive information but noted that GMC is renewing its focus on the project. ISIF maintains ongoing and regular engagement with the company and its shareholders with respect to the proposed development.

On 11 January this year the U.S. investors in GMC updated on their investment me as part of a programme of meetings that I was involved while visiting the U.S. West Coast. 

Departmental Data

Questions (196)

Richard Bruton

Question:

196. Deputy Richard Bruton asked the Minister for Finance if he will outline the number of payments made under the Help to Buy Scheme and their average value to date for each county, in tabular form. [25420/24]

View answer

Written answers

I am advised by Revenue that the table below presents a geographical breakdown of the total number of approved Help to Buy claims. The table outlines the number of approved claims as well as total and average claim amount (payments) as of 6 June 2024.

County

Number

Claim Amount (€m)

Average Claim Amount (nearest hundred)

Carlow

481

9.5

19,700

Cavan

453

8.6

18,900

Clare

814

17.0

20,900

Cork

6,300

142.1

22,600

Donegal

824

14.9

18,100

Dublin

9,671

205.2

21,200

Galway

2,294

49.4

21,500

Kerry

587

11.2

19,100

Kildare

5,866

135.7

23,100

Kilkenny

771

17.2

22,200

Laois

1,105

23.3

21,100

Leitrim

130

2.5

18,900

Limerick

1,499

31.7

21,200

Longford

171

3.2

18,700

Louth

1,837

37.2

20,200

Mayo

927

18.4

19,800

Meath

5,268

108.7

20,600

Monaghan

488

9.5

19,500

Offaly

725

16.0

22,000

Roscommon

413

8.3

20,000

Sligo

386

7.5

19,500

Tipperary

771

14.9

19,400

Waterford

1,231

24.0

19,500

Westmeath

713

15.3

21,500

Wexford

1,541

31.9

20,700

Wicklow

2,180

48.9

22,400

Total

47,446

1,012*

21,300

*rounded.

Housing Schemes

Questions (197)

Niall Collins

Question:

197. Deputy Niall Collins asked the Minister for Finance further to Parliamentary Question No. 183 of 7 December 2023, if any further consideration has been given to this issue; and if he will make a statement on the matter. [25436/24]

View answer

Written answers

In relation to the Deputy's query about the of lowering the LTV ratio for the Help to Buy Scheme, the position remains as set out in my answer to Parliamentary Question no. 183 of 7 December 2023 and my answer to Parliamentary Question No. 218 of 16 April 2024 and I have no plans to change the LTV ratio as proposed.

Notwithstanding this, it should be noted that decisions regarding taxation measures are usually made in the context of the annual Budget and Finance Bill process and at the appropriate time. Such decisions also must have regard to the sound management of the public finances and my Department's Tax Expenditure Guidelines.

I will continue to work with my cabinet colleagues to ensure that any further interventions in the housing market are appropriately calibrated, represent the best use of scarce public resources and boost the supply of housing in both the public and private sectors.

Departmental Contracts

Questions (198)

Catherine Murphy

Question:

198. Deputy Catherine Murphy asked the Minister for Finance if he will provide a schedule of all contracts they have and/or had with a company in the past 25 years to date (details supplied); the agreed contract cost; the ultimate contract cost including extras, design changes, conciliation, claims etc; project name/title; and the name of the body responsible for the delivery of projects where responsibility has been devolved. [25474/24]

View answer

Written answers

The ‘National Public Procurement Policy Framework’ issued by the Office of Government Procurement (OGP) sets out the procurement procedures to be followed by government departments and state bodies in accordance with EU rules and national guidelines.

In addition, my Department has its own internal policy and guidance documents to assist staff to comply with all procurement regulations.

I am informed that my Department has not awarded any contracts to the company named by the Deputy in the period from 2004 to date. It has not been possible to collate and examine all material for the remaining 5 years, from 1999 to 2003 inclusive, in the time available.  I will write to the Deputy directly once the information is to hand.

Universal Social Charge

Questions (199)

Jackie Cahill

Question:

199. Deputy Jackie Cahill asked the Minister for Finance if a person is in receipt of a medical card, do they pay a lower rate of universal social charge; and if he will make a statement on the matter. [25496/24]

View answer

Written answers

Individuals who hold a full medical card with total income of €60,000 per annum or less may benefit from reduced rates of Universal Social Charge (USC). 

To qualify for the reduced USC rates the individual does not need to hold the medical card for the full year, the reduced rates apply once the individual holds a full medical card for any period during the year.  The reduced rates of USC that apply for 2024 are 0.5 per cent on the first €12,012 of income and 2 per cent on the balance. Taxpayers that can avail of this concession are not subject to the 4 per cent USC rate of charge, as would be the case for all other taxpayers.  

Tax Code

Questions (200)

Seán Canney

Question:

200. Deputy Seán Canney asked the Minister for Finance the reason recycled plastic water drinking troughs are not included in the list of components that a farmer can reclaim VAT on; and if he will make a statement on the matter. [25508/24]

View answer

Written answers

The VAT treatment of goods and services is subject to EU VAT law, with which Irish VAT law must comply.  In accordance with the EU VAT Directive, farmers can elect whether or not to register for VAT in respect of their farming business, and each farmer’s decision on this matter affects how VAT incurred on their inputs (such as the purchase of farm equipment) is treated.

Under VAT law, unregistered farmers can avail of the Flat-rate Farmers Scheme.  This arrangement, which is unique to the farming sector, allows farmers to choose to remain unregistered for VAT and yet be compensated on an overall basis for the VAT they incur in the course of their business, while still remaining outside the VAT system and avoiding the burden of registration and filing.  The Scheme is designed as an administrative simplification measure and allows unregistered farmers to add and retain a percentage charge (known as the “flat-rate addition”) onto the amount they invoice VAT-registered businesses whom they supply with agricultural goods and services in the course of their farming business. As is normal for VAT-unregistered businesses, unregistered farmers are not entitled to reclaim VAT incurred on the various individual inputs used in their farming business. 

There are certain limited situations, however, in which flat-rate farmers are specifically permitted by law to claim a refund of the VAT incurred by them on particular inputs.  The Value-Added Tax (Refund of Tax) (Flat-rate Farmers) Order 2012 (S.I. No. 201/2012) is the relevant legislation.  It allows for refunds to be claimed by VAT-unregistered farmers in relation to outlay on the following only:

• the construction, extension, alteration or reconstruction of a farm buildings or structures.

• the fencing, draining and reclamation of farmland; and

• the construction and/or installation of qualifying equipment for the purpose of micro-generation of electricity for use in a farm business.

Farming structures are man-made structures that are fixed to, or in, the ground and which cannot be easily dismantled or moved, such as farm roads, farmyards, and silage pits. A recycled plastic water drinking trough is not typically considered a farm structure. Instead, it is considered a piece of farm equipment, or a container used on a farm.  This means that the purchase of a recycled plastic water drinking trough would not come within the scope of the Refund Order.

Revenue published a Tax and Duty Manual (TDM) on 4 June 2024 to provide further guidance on the Refund Order. The TDM outlines how VAT can be reclaimed under the Refund Order by flat-rate farmers, the conditions under which VAT may be reclaimed, guidance on the types of expenditure on which VAT can and cannot be reclaimed, and the information required to make a claim.

The TDM explains that VAT may be refunded in circumstances where goods, which themselves are outside the scope of the Refund Order, are installed into a farm building in such a way that they become a fixture.  The concept of what constitutes a fixture and what is merely a fitting is well-established in VAT rules.  Fixtures are goods which have become closely linked to or integrated into a building in such a way that they cannot be removed without substantial damage or significant alteration being caused to the goods themselves or to the building or construction to which they are installed.

Sections 5.7, 5.9 and 5.9.2 of the Revenue guidance document provide further detail on this matter.  To qualify under the Order, the farming equipment or machinery would need to be permanently installed in a newly constructed / altered or extended farm building and once installed, cannot be removed without causing significant alteration, substantial damage, or destruction to the farm building or to the equipment or machinery itself. Minor changes such as items nailed, screwed, or bolted to the building walls or floor would not be considered an alteration for the purposes of the order.  Also, Revenue will consider the effort, time, cost, and impact on the equipment itself to determine if there is significant alteration, substantial damage or destruction of the farm building or structure or to the equipment itself.  Equipment that can be removed and re-sold intact and used for its original purpose will not be eligible for a refund. Mobile equipment or machinery is not refundable under the Order.

On this basis, it is not likely that an installed recycled plastic drinking trough would constitute a fixture and, therefore, it is unlikely to be eligible for a refund.  However, each claim is assessed on its own merits.  Claimants are encouraged to provide supporting documentation, photos, detailed description of works carried out to the building or structure to allow for the installation of fixtures and any contracts associated with same when submitting their claims.

Where the equipment is not refundable under the Order, any construction, reconstruction or alteration work related to the installation of the equipment into the farm building or structure may be allowed. Claimants should provide details of the works carried out, invoices and photographs.

Finally, the Deputy may wish to note, that it is always open to a farmer to elect to register for VAT in respect of their farming business.  VAT-registered businesses are entitled to claim a full deduction for the VAT they incur on their business costs, subject to rules on deducibility.

Tax Code

Questions (201)

Bernard Durkan

Question:

201. Deputy Bernard J. Durkan asked the Minister for Finance the status of any debt for local property tax owed in the case of a person (details supplied) given there was a delay in her receiving a PPS number following the death of her spouse; and if he will make a statement on the matter. [25515/24]

View answer

Written answers

I am advised by Revenue that the ownership of the property concerned was updated on 8 February 2024 to reflect the individual as the designated liable person of the property for Local Property Tax (LPT) purposes.

Revenue have confirmed that LPT payments and returns have been received for all years and the LPT property record is in order. 

Should the person concerned have any further queries regarding LPT, they can contact Revenue via the LPT Helpline on (01) 738 36 26, from 9:30am-4:30pm, Monday to Friday.

Tax Data

Questions (202)

Pearse Doherty

Question:

202. Deputy Pearse Doherty asked the Minister for Finance if the residential premises rental income relief is in the tax base, under the stability programme update, in each of the years 2025, 2026 and 2027, respectively; and the amount in the base for each of those years. [25520/24]

View answer

Written answers

At the time of Budget 2024 the residential premises rental income relief was estimated to cost €45 million in 2024, rising to €160 million in 2027.

The estimated cash cost of this measure at Budget time is reflected in the no-policy-change Stability Programme Update projections for tax revenue, as set out in the table below.

 -

2025

2026

2027

cost €m

112

114

160

Tax Data

Questions (203)

Catherine Murphy

Question:

203. Deputy Catherine Murphy asked the Minister for Finance the amount of income received from the betting levy in 2023 and for the first five months of 2024, in tabular form. [25530/24]

View answer

Written answers

I am advised by Revenue that a breakdown of Betting Duty receipts is published on the Revenue website at: www.revenue.ie/en/corporate/information-about-revenue/statistics/excise/betting-duty/index.aspx.

The published data are to the end of April 2024. I am further advised by Revenue that betting duty returns and payments are due quarterly, and the data are published on this basis.

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