Written Answers Nos. 812-833
812. Deputy Mairéad Farrell asked the Tánaiste and Minister for Finance if his attention has been drawn to the Karshan Disclosure Opportunity Guidance; if the Government has assessed whether this scheme complies with EU law (Art. 31 Charter, Directive 2003/88/EC). [74843/25]
View answerI thank the Deputy for her question.
At the outset, I must remind the Deputy that the principle of the independence of the Revenue Commissioners in their dealings with the tax affairs of any individuals, business or other entity under tax and customs legislation is critical to maintaining the integrity of the taxation system. Legal effect in this matter is provided under Section 101 of the Ministers and Secretaries (Amendment) Act, 2011. This provision ensures that neither article 9 of the Revenue Commissioners Order 1923 nor section 9(3) of the Ministers and Secretaries Act 1924, which relate to Ministerial responsibilities and controls, can apply to the Revenue Commissioners when performing their functions under tax and customs legislation including their handling of the Karshan Disclosure Opportunity.
However, by way of context, following the 2023 Supreme Court judgement on the Revenue Commissioners v Karshan (Midlands) Ltd T/A Domino's Pizza case, all businesses who were engaging contractors, sub-contractors or other workers on a self-employment basis were encouraged by Revenue to familiarise themselves with the detail of the judgment and review their workforce model in light of same. In May 2024, Revenue published a detailed Tax and Duty Manual (TDM) 05-01-30 ‘Revenue Guidelines for Determining Employment Status for Taxation Purposes’ which assists employers to understand their tax obligations by outlining the implications of the five-step framework, including detailed explanations of each step and examples. Prior to the publication of this Tax and Duty Manual, Revenue sought input from Government agencies and from other relevant external stakeholders, including trade union bodies, on the development of the guidelines.
Revenue recognised that prior to the judgment some employers, acting in good faith, may have misclassified employees for tax purposes as persons engaged in contracts for services.
In this context, in September 2025, Revenue announced a disclosure initiative aimed at employers who are potentially impacted by the Supreme Court judgment. This initiative incentivises such employers to make a disclosure in respect of 2024 and 2025 arising from bona-fide classification errors. Employers who acted in good faith relying on the case law and guidance available prior to the Karshan judgment, may have misclassified employees as contractors. Such employers were encouraged to review their workforce model in light of the 5-step model outlined in the Supreme Court judgement and if necessary, to regularise their tax position.
Detailed guidance on this disclosure opportunity is set out in Tax and Duty Manual ‘Settlement arrangement arising from Revenue v Karshan (Midlands) Ltd. trading as Domino’s Pizza’ which is available at: www.revenue.ie/en/tax-professionals/tdm/compliance/audit-and-other-compliance-interventions/karshan-settlement-guidance/karshan-disclosure-opportunity-guidance.pdf In the course of the design and development of this disclosure initiative, Revenue consulted via the Tax Administration Liaison Committee (TALC) Audit with the professional tax advisor, accounting and legal bodies who are members of TALC.
There are a number of exclusions from the disclosure initiative, including where Revenue is of the opinion that the misclassification has arisen from either careless or deliberate behaviour (in the context of Revenue’s Code of Practice for Revenue Compliance Interventions). In such cases the benefit of the initiative is not afforded and the full liability to Income Tax, USC and PRSI and interest and penalties will be pursued.
In addition, should an employer fail to take this opportunity to review its workforce practices and to make a disclosure to Revenue if required to do so by the deadline of 30 January 2026, Revenue may initiate an inquiry or investigation. If misclassification is subsequently identified in the course of that inquiry or investigation, Revenue will form the view that the default has arisen from a complete failure to operate fiduciary taxes and will apply the relevant legislation in relation to the failure to deduct PAYE, PRSI and USC. Interest and penalties will be applied in full in line with the relevant legislation and Revenue’s Code of Practice for Revenue Compliance Interventions which is available at: www.revenue.ie/en/tax-professionals/documents/code-of-practice-revenue-compliance-interventions.pdf
Regarding the Deputy's reference to EU law (Art. 31 Charter, Directive 2003/88/EC) - known as the Working Time Directive - it is important to note that Revenue has responsibility for employment status for taxation purposes only, but has no role in relation to workers’ entitlements. As the Deputy is aware, there are a number of other statutory bodies whose remit includes determining the employment status of a person. The Department of Social Protection (DSP) determines employment status with a view to deciding the appropriate class of PRSI for an individual. Responsibility for a range of employment rights, such as employment equality, minimum wage rates, holiday pay, sick pay, maternal and paternal leave, sectoral pay agreements, etc., falls to the Workplace Relations Commission (WRC) under the aegis of the Department of Enterprise, Trade and Employment. The WRC’s Adjudication Service determine employment status as a preliminary issue when adjudicating on employment rights complaints.
Each of these bodies make their determinations independently of each other in respect of the particular functions for which they are responsible, based on the separate legislative frameworks that apply. As such, it should be noted that a decision by one body is non-binding on the other two bodies. The responsibilities of each body in relation to employment status are outlined in the updated Code of Practice on Determining Employment Status (“the Joint Code”), which was jointly published in November 2024 by DSP, the WRC and Revenue. The Joint Code is available at: assets.gov.ie/static/documents/code-of-practice-on-determining-employment-status-cb301d37-93cb-4fbf-b45c-6997ed370f04.pdf
I note the Deputy refers particularly to Article 31 of the Working Time Directive (Directive 2003/88/EC). I understand that this Directive lays down minimum safety and health requirements for the organisation of working time. The competent authority for this and other workers’ rights under EU legislative instruments is the Department of Enterprise Trade and Employment. As outlined above, my Department and Revenue have no role in relation to worker’s rights and the Karshan Disclosure opportunity has no bearing on such rights or entitlements.
813. Deputy Mark Wall asked the Tánaiste and Minister for Finance the cost of making the carer’s allowance, including the half-rate carer’s allowance, exempt from tax; and if he will make a statement on the matter. [1960/26]
View answerI am advised by Revenue that the income tax liability arising from the taxation of carer’s allowance is not separately determinable as it is calculated based on the circumstances of each individual taxpayer. Therefore, it is not possible to identify the amount of tax foregone if the carer’s allowance was exempt from income tax.
814. Deputy Carol Nolan asked the Tánaiste and Minister for Finance the reason his predecessor effectively vetoed a proposal to borrow €100 million for defence spending under the Security Action for Europe (SAFE) programme; and if he will make a statement on the matter. [73918/25]
View answerAs announced on 27 June, Ireland will be leveraging the common procurement opportunities offered under the SAFE instrument to speed up delivery of Ireland’s defence capability.
Ireland did not seek to draw down funding from SAFE at this time, this decision followed engagement between the Department of Defence, the Department of Public Expenditure, Infrastructure, Public Service Reform and Digitalisation, and the Department of Finance.
This decision reflected the recent Government agreement on the National Development Plan, which sets out a capital allocation for the Defence Vote Group for the period 2026-2030 of €1.7 billion, an increase of 55 per cent on the previous baseline.
815. Deputy Marie Sherlock asked the Tánaiste and Minister for Finance the cost of extending the scope of tax relief at the standard rate of tax to routine dental treatment to cover preventative and rehabilitative treatments currently excluded including direct restorations (fillings within the mouth), all extractions and dentures; and if he will make a statement on the matter. [73940/25]
View answer816. Deputy Marie Sherlock asked the Tánaiste and Minister for Finance the cost of restoring tax relief at the marginal rate of tax for existing non routine dental treatment for which income tax relief at the standard rate of tax is currently available; and if he will make a statement on the matter. [73941/25]
View answerI propose to take Questions Nos. 815 and 816 together.
Section 469 of the Taxes Consolidation Act (“TCA”) 1997 provides for tax relief where an individual proves that they have incurred costs in respect of qualifying health expenses. Only “health expenses” incurred in the provision of “health care”, which has been carried out or advised by (in certain circumstances) a “practitioner”, will qualify for tax relief.
Health care is defined as the “prevention, diagnosis, alleviation or treatment of an ailment, injury, infirmity, defect or disability”. Health expenses are defined as “expenses in respect of the provision of health care” and include "expenses representing the cost of maintenance or treatment necessarily incurred in connection with the services of a practitioner".
As per section 469 TCA 1997, “routine dental treatment” is defined as “the extraction, scaling and filling of teeth and the provision and repairing of artificial teeth or dentures”.
This section specifically excludes “routine dental treatment” from the definition of “health care”. As a result, routine dental treatment does not qualify for tax relief on health expenses.
However, tax relief may be available in respect of non-routine dental treatment. While non-routine dental treatment is not defined in the legislation, the list of dental treatments for which relief is allowed is included on the Form MED 2, which can be accessed on the Revenue website linked below. To claim tax relief on a dental treatment, the Form MED 2 must be signed and certified by the relevant dental practitioner and provided to the taxpayer for onward submission to Revenue if required.
Tax relief on health expenses is currently granted at the standard rate of tax (20%) generally.
With regard to the cost of extending the scope of tax relief to routine dental treatments, I am advised by Revenue that as this expense is outside the scope of the current tax relief, Revenue does not have any expenditure data on these treatments from which to estimate a cost.
Secondly, due to the way non-routine dental expenses and ‘other’ health expenses are claimed and recorded, data on specific qualifying health expenses, such as non-routine dental treatments, is not available for statistical analysis. Thus it is not possible to estimate the cost associated with altering the rate of relief applicable to this specific category of health expenses.
I would note that the relief currently provides a significant level of support, in 2023 the latest year for which data is available, the cost of tax relief for health expenses (excluding nursing home expenses) was €223.3 million and it was availed of by 706,300 claimants. The estimated total cost of tax relief for health expenses is available on the Revenue website: www.revenue.ie/en/corporate/information-about-revenue/statistics/tax-expenditures/cost/index.aspx
Further guidance on tax relief for qualifying health expenses can be found at the following links:
• Revenue’s Tax and Duty Manual Part 15-01-12: www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-15/15-01-12.pdf
• On the Revenue website: www.revenue.ie/en/personal-tax-credits-reliefs-and-exemptions/health-and-age/health-expenses/dental-expenses.aspx
• Form MED 2: www.revenue.ie/en/personal-tax-credits-reliefs-and-exemptions/documents/med2.pdf
817. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance the safeguards and oversight mechanisms in place to ensure special purpose entities/section 110 companies are only used to create a bona fide securitisation and structured finance; the number of SPEs/S.110 companies that have had their registration as an SPE/S.110 company revoked or declined, in tabular form; and if he will make a statement on the matter. [74049/25]
View answerA Special Purpose Entities (“SPE”) is a company specially created to fulfil a narrow, specific purpose. The reasons for setting up an SPE include holding pools of assets as security for loans and creating liquidity for entities. Section 110 of the Taxes Consolidation Act (TCA) 1997 sets out the Irish regime for the taxation of qualifying companies set up to securitise assets.
The Central Bank of Ireland (“Central Bank”) and Revenue both have a role in relation to the oversight of SPEs.
I am informed by the Central Bank that, from a safeguarding and oversight perspective, it focuses on the securitisation activity itself and on regulated firms that originate, sponsor, invest in, or distribute securitisations. Oversight is applied through EU and domestic regulatory frameworks rather than through the tax status of the vehicle.
Where a structure is considered to not meet securitisation requirements (e.g., fails risk retention, transparency or due diligence tests), Irish regulated firms can be restricted from originating, sponsoring, investing in or distributing it, and may face supervisory action for breaches. I am informed by the Central Bank that some of the safeguards and oversight mechanisms available to it include:
• EU Securitisation Regulation (SR) supervision
- Risk retention: Irish originators/sponsors and EU institutional investors must ensure a minimum 5% net economic interest is retained; non-compliant deals are effectively off-limits for regulated investors.
- Transparency: Article 7 reporting (loan-level/performance data, transaction documents, significant events) to investors, securitisation repositories and authorities. The Central Bank has access to this data for Irish-relevant transactions and challenges gaps.
- Investor due diligence: Banks, insurers, Undertakings for Collective Investment in Transferable Securities (UCITS)/ Alternative Investment Fund Managers (AIFMs) and investment firms must assess asset quality, structural features, servicing, and ongoing reporting before and after investing.
- STS regime: If labelled Simple, Transparent and Standardised (STS), deals must meet additional criteria; the Central Bank can verify and take action if firms misuse the label.
- Enforcement: Irish law designates the Central Bank as a competent authority for the SR [alongside the European Central Bank (ECB)]. The Bank can request information, conduct inspections and apply administrative sanctions for breaches by Irish-regulated firms.
• Prudential and conduct frameworks that constrain participation in non-bona fide structures
- Banks (Capital Requirements Regulation and the Capital Requirements Directive, with ECB oversight for significant institutions and Central Bank of Ireland for less significant): Securitisation capital charges, due diligence tests, and disclosure requirements; non-compliant exposures attract punitive treatment or are prohibited.
- Insurers (Solvency II): Strict capital/due diligence rules for securitisation holdings, with additional conditions for STS.
- Investment firms and funds [Markets in Financial Instruments Directive (MiFID), Alternative Investment Fund Managers Directive (AIFMD)/UCITS]: Organisational, product-governance and investor-protection rules; AIFMs/UCITS managers are subject to SR investor due diligence and ongoing monitoring requirements.
- Market conduct: The Central Bank is the competent authority for the Prospectus regime (where applicable), Market Abuse Regulation and Transparency rules for Irish-listed or offered securities, providing ex-ante disclosure checks and ongoing market oversight.
• Statistical reporting and surveillance of Irish SPVs used in securitisation
- Financial Vehicle Corporations (FVCs): SPVs that meet the ECB FVC definition must register and file periodic statistical returns to the Central Bank. These data (assets, liabilities, flows, counterparties) underpin surveillance of market-based finance, interconnectedness with banks and funds, and risk assessments.
- The Bank uses these data, along with repository and market information, to target reviews and thematic work on securitisation practices.
• Anti Money Laundering (AML)/ Countering the Financing of Terrorism (CFT), beneficial ownership and transparency measures
- Regulated firms that arrange, manage, service or distribute securitisations are supervised by the Central Bank for AML/CFT compliance.
- Companies (including Section 110 SPVs) must file beneficial ownership information to the central register, increasing transparency of control; service providers are subject to customer due diligence and reporting obligations.
• Supervisory tools and coordination
- Tools: Information-gathering powers, desk-based reviews, on-site inspections, directions, risk-mitigation programmes, and administrative sanctions against Irish-regulated originators, sponsors, arrangers and institutional investors.
- Coordination: Ongoing cooperation with EU authorities (ESMA, EBA, ECB/ Single Supervisory Mechanism) and domestic counterparts (e.g., Revenue on tax matters) to share intelligence and ensure consistent application.
The Central Bank informs me that where a structure is considered to not meet securitisation requirements (e.g., fails risk retention, transparency or due diligence tests), Irish regulated firms can be restricted from originating, sponsoring, investing in or distributing it, and may face supervisory action for breaches.
I am informed by Revenue that Section 110 TCA 1997 sets out a number of conditions which a company must meet in order to be a qualifying company. For example, there is a requirement for the company to be tax resident in the State and a company must notify an authorised officer in Revenue within the specified timeframe that (i) it is, or intends to be, a 'qualifying company', and (ii) it meets the conditions outlined in legislative provisions. Where the authorised officer is satisfied the conditions are met at the notification stage, the company is added to Revenue’s internal Section 110 register. The number of notifications which were declined as the necessary conditions were not met for each of the years from 2021 to 2024 was less than 10.
I am informed by Revenue that as part of its compliance programme, Revenue undertakes compliance projects to satisfy itself as to the accuracy or otherwise of returns filed by qualifying companies, having regard to the requirements set out in section 110. Before any case goes to intervention, Revenue first carries out an appraisal where it considers whether risk exists in the case and if so the level of tax risk. In 2024, 1,202 appraisals were completed on qualifying companies with 1,489 completed in 2025. Recognising that there are varying degrees of risk in terms of complexity and materiality within individual cases, Revenue initiates a range of compliance interventions into qualifying companies. In 2024, 209 compliance interventions were completed on qualifying companies. In 2025, 155 compliance interventions were completed on qualifying companies.
818. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance the estimated share of the €1.24 trillion in assets now held in Irish special purpose entities/section 110 companies related to the Irish economy and economic activity in this State; and if he will make a statement on the matter. [74050/25]
View answer820. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance to provide the number of charitable trusts that own special purpose entities/section 110 companies; the number of SPEs owned by each charitable trust, in tabular form; and if he will make a statement on the matter. [74052/25]
View answerI propose to take Questions Nos. 818 and 820 together.
I am advised by the Central Bank of Ireland(CBoI) that it does not publish information related to the economic activity of Special Purpose Entities (“SPEs”) and therefore a breakdown of the share of assets held in SPEs according to economic activity cannot be provided.
819. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance if he will provide the total number of non-Irish domiciled companies i.e. incorporated in another jurisdiction but fulfil the tax residency test in Ireland; the number of non-domiciled section 110 companies; and if he will make a statement on the matter. [74051/25]
View answer821. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance the total corporation tax paid by special purpose entities/section 110 companies for the most recent year data is available; and if he will make a statement on the matter. [74053/25]
View answerI propose to take Questions Nos. 819 and 821 together.
Section 110 of the Taxes Consolidation Act (TCA) 1997 sets out the Irish regime for the taxation of qualifying companies set up to securitise assets. Section 110 TCA 1997 sets out a number of conditions which a company must meet in order to be a qualifying company, including the requirement to be tax resident in the State.
Measures were introduced in Finance Act 2014 implementing changes to tax residence rules and these changes are reflected in section 23A TCA 1997. These measures ensure that a company incorporated in the State is regarded as resident for tax purposes in the State, unless it is treated as resident in a treaty partner country by virtue of a double taxation treaty.
Before these rules were introduced a company was regarded as resident in Ireland if its central management and control was performed in Ireland. The changes introduced in Finance Act 2014 do not prevent a foreign incorporated company that is centrally managed and controlled in the State being resident in the State for tax purposes. Therefore, a company which is incorporated in another jurisdiction but managed and controlled in the State is regarded as being tax resident and subject to corporation tax in Ireland on its profits.
I am informed by Revenue that, based on the information contained in corporation tax returns filed, the total number of companies and qualifying companies’ resident in Ireland but incorporated in another jurisdiction is set out in the table below for the years 2020 to 2023 inclusive:
|
Year |
Irish tax resident companies incorporated outside the State |
Irish tax resident qualifying companies incorporated outside the State |
|
2023 |
2,035 |
69 |
|
2022 |
1,969 |
74 |
|
2021 |
1,753 |
72 |
|
2020 |
1,772 |
63 |
I am advised by Revenue that information in respect of 2025 corporation tax payments is not yet available. It will be published in 2026 once the relevant analysis is completed.
In relation to 2024, the most recent year for which data is available, the amount of gross corporation tax receipts paid by qualifying companies amounted to €90 million.
Information in respect of corporation tax paid by qualifying companies is provided in Revenue’s “Corporation Tax 2024 Payments and 2023 Returns” statistical report. This report is published on the Revenue website at: www.revenue.ie/en/corporate/documents/research/ct-analysis-2025.pdf
822. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance to set out the procedure for suspending a double taxation treaty; and if he will make a statement on the matter. [74054/25]
View answerA double taxation treaty is an international agreement entered into between two States and is governed by public international law and specifically by the Vienna Convention on the Law of Treaties of 1969, which entered into force on 27 January 1980 (“Vienna Convention”). The Vienna Convention codified existing norms of customary international law. Ireland accepts the principles of international law under Article 29.3 of the Constitution; Article 29.6 of the Constitution provides that the Oireachtas determines how international agreements are brought into domestic law.
Section 826 of the Taxes Consolidation Act of 1997 gives Ireland’s double taxation treaties legal effect under domestic legislation.
In negotiating double taxation treaties, Ireland, as a member of the Organisation for Economic Cooperation and Development (OECD), uses the OECD Model Tax Convention (MTC), adapting it, as appropriate, to Ireland’s domestic requirements.
Article 32 of the OECD MTC relates to “Termination” and provides that a double taxation treaty shall remain in force until terminated by a Contracting State.
It is Ireland’s policy to include such a termination provision in its double taxation treaties. While the specific text may vary from treaty to treaty, in general terms, the “Termination” Article provides that either Contracting State may terminate the treaty at any time after five years from the date on which the treaty enters into force, provided that at least six months prior written notice of termination has been given through diplomatic channels.
These “Termination” Articles are prescriptive in setting out when a treaty can be terminated and the date from which such a termination will take effect. To the extent that a treaty is terminated, it cannot be revived without a full renegotiation.
While a “Termination” Article is a standard element of both the OECD’s and UN’s model tax conventions, neither model provides for the suspension of a treaty. Therefore, Ireland’s double taxation treaties do not provide for suspension of the treaty by either Contracting State.
Article 60 of the Vienna Convention provides that “[a] material breach of a bilateral treaty by one of the parties entitles the other to invoke the breach as a ground for terminating the treaty or suspending its operation in whole or in part”. Article 60 is not prescriptive in terms of the date of effect of the suspension, or the possibility of reactivating the treaty.
823. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance the percentage share and value of securitised mortgages held by each bank in the State; the share of securitised mortgages that have been used as collateral with the ECB; and if he will make a statement on the matter. [74055/25]
View answerWith regards to the first part of your question on percentage share and value of securitised mortgages held by Irish banks, the Central Bank of Ireland has provided the following overview of the volumes of securitised mortgage assets (across securitisations) on the banks’ balance sheet, based on the latest available information:
• AIB: €6,952 million – 19% of the total mortgage portfolio (as of December 2025).
• BOI: €15,703 million – 31% of the total mortgage portfolio (as of June 2025).
• PTSB: €4,833 million – 23% of the total mortgage portfolio (as of June 2025).
Securitised mortgages are generally held on the balance sheets of retail banks in order to act as contingent liquidity (under the Eurosystem collateral framework) for accessing Central Bank borrowing facilities. While the Central Bank collects data on securitised mortgages held by Irish banks that have been used as collateral with the ECB, this data is not published given its commercial sensitivity.
824. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance further to Parliamentary Question No. 252 of 20 March 2025, the reason Jersey does not appear on the list of double taxation agreements; if other jurisdictions have not been included; and if he will make a statement on the matter. [74056/25]
View answerTax treaties provide greater certainty and fairness for taxpayers regarding their tax obligations in foreign jurisdictions, and they are key to the prevention of double taxation. It is Ireland's policy to treat negotiations for tax treaties as confidential until they are signed, at which point they are published on Revenue's website. This is standard practice for most jurisdictions.
Ireland has signed 78 comprehensive double taxation treaties, 75 of which are in effect*: inance.cloud.gov.ie/apps/eDocs/s/F585/Files/F585-007-2019/2025/260112%2074056-25%20PQ%20REF.docx#_ftn1
Ireland has tax treaties with all EU Member States and all OECD member countries, bar the two newest members (Colombia and Costa Rica).
The text of each of Ireland’s double taxation treaties is available at: www.revenue.ie/en/tax-professionals/tax-agreements/double-taxation-treaties/tax-treaties-by-country.aspx, with the dates of effect of those treaties available at: www.revenue.ie/en/tax-professionals/tax-agreements/dates-of-effect/index.aspx
Jersey are not included on this list as the agreements in place between Ireland and Jersey do not represent a comprehensive double taxation treaty but rather include a Tax Information Exchange Agreements (TIEA) alongside what is referred to as a “Limited Scope Agreement”.
Ireland is committed to the full exchange of tax information and, in addition to its extensive comprehensive tax treaty network, Ireland has concluded Tax Information Exchange Agreements (TIEAs) with 26 countries and autonomous regions, all of which are in effect. The TIEAs concluded by Ireland are based on the OECD model TIEA which grew out of the work undertaken by the OECD to address harmful tax practices globally and represents the international standard for effective exchange of information in tax matters.
Ireland’s list of TIEAs is published at: www.revenue.ie/en/tax-professionals/tax-agreements/tiea/index.aspx?page=g
Among the 26, is an agreement with Jersey.
In parallel with the conclusion of the TIEA, it was also recognised that taxation obstacles may, in certain circumstances, hinder trade and the free movement of individuals between Ireland and Jersey. Accordingly, alongside the TIEA, an agreement for ‘affording relief from double taxation with respect to certain income of individuals and establishing a mutual agreement procedure in connection with the adjustment of profits of associated enterprises’ was also entered into with Jersey (this type of an agreement, which is not a comprehensive double taxation treaty and is often referred to as a “Limited Scope Agreement” as outlined above).
This Agreement is, as stated, limited in scope and prevents double taxation of certain sources of income of individuals, in particular, pensions from past employment, salaries and pensions of government employees, and income of students. There is also a provision in the Limited Scope Agreement with Jersey to allow both countries to resolve cases of potential double taxation arising from the adjustment of profits of companies by way of a mutual agreement procedure.
However, provisions in respect of immovable property, business profits, dividends, interest, royalties, capital gains, income from employment, directors’ fees, etc. are absent from all Limited Scope Agreements.
The Limited Scope Agreement with Jersey was approved by the Oireachtas in 2009. The text of the Limited Scope Agreement with Jersey is available at: www.revenue.ie/en/tax-professionals/tax-agreements/tiea/index.aspx?page=j, alongside the TIEAs.
Subsequently, and in order to incorporate the tax treaty-related minimum standards, agreed as part of the G20/OECD Base Erosion and Profit Shifting (BEPS) project, into the Limited Scope Agreements, including the one with Jersey, Protocols to the Agreements were negotiated between the parties to include the necessary BEPs related modifications. The Protocol with Jersey was approved by the Oireachtas in 2024.
Jersey, Guernsey and the Isle of Man are the only regions with which Ireland has entered into such Limited Scope Agreements.
*Treaties with Ghana, Kenya and Liechtenstein have yet to be ratified.
825. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance for a breakdown of market assets pledged by Irish banks to the ECB as collateral by Government securities, asset-back securities, corporate bonds, banks bonds etc. [74057/25]
View answerWhile the Central Bank of Ireland collects data on market assets held by Irish banks that have been used as collateral with the ECB, this data is not published given its commercial sensitivity. However, I am informed by the Central Bank that the ECB publishes a quarterly breakdown of pledged collateral at Eurosystem level - www.ecb.europa.eu/mopo/coll/charts/html/index.en.html. This data is not available at jurisdiction level.
Eurosystem borrowings at country level are published by the ECB on a monthly basis and are included in the disaggregated financial statements data - www.ecb.europa.eu/press/annual-reports-financial-statements/wfs/dis/html/index.en.html. As at 28 November 2025, Eurosystem borrowings drawn in Ireland amounted to €1million.
826. Deputy Sinéad Gibney asked the Tánaiste and Minister for Finance to provide a list of AI pilot projects which have taken place in his Department within the past 12 months; the expenditure associated with those projects; and whether they are still ongoing, in tabular form. [74133/25]
View answerI wish to advise the Deputy that my department follows the Guidelines for the Responsible Use of Artificial Intelligence in the Public Service, published in May 2025. In doing so, my department recognises the opportunities AI presents to help improve the delivery of public services to our citizens. In addition, my department follows guidance from the National Cyber Security Centre (NCSC) including “Cyber Security Guidance on Generative AI for Public Sector Bodies” released in June 2023. The NCSC guidance recommended that new technology should only be adopted based on a clearly defined business needs following an appropriate risk assessment.
I can confirm for the Deputy that no AI pilot projects have taken place in my department within the past 12 months.
I can also confirm that my department recently developed an Interim Strategy on the Adoption and Use of AI within the Department which has been circulated to all staff. In December 2025, access to Microsoft Copilot Chat was provided to all staff.
827. Deputy Sorca Clarke asked the Tánaiste and Minister for Finance whether standards or service-level targets exist for his Department or bodies under the aegis of his Department, in responding to correspondence from members of local authorities; if compliance with such standards is monitored; the reasons for delays or failures to respond to correspondence from elected members; and the measures being taken to ensure more consistent and timely communication going forward. [74271/25]
View answerMy Department revised its Customer Action Plan and Charter in 2024. The Charter governs the period 2024 to 2026 and outlines the Department's commitment to the principles of quality customer service. This document is available on the Department’s website www.gov.ie/en/department-of-finance/organisation-information/quality-customer-service/.
The Department is a member of the Quality Customer Service Network along with other civil and public service bodies. All customer correspondence, including correspondence received from elected members is handled in line with the Customer Charter and in accordance with data protection requirements. Customer service processes are kept under review.
The following information has been provided by the Bodies under the Aegis of the Department.
Central Bank
The Central Bank of Ireland maintains a service level agreement (SLA) for responding to correspondence from elected officials, including members of local authorities. Compliance with the standards contained in the SLA is monitored. Response timelines in relation to correspondence from members of local authorities are met. The SLA is kept under review.
National Treasury Management Agency (NTMA)
The NTMA does not operate defined standards or formal service-level targets for responding to correspondence from members of local authorities. More generally, the NTMA deals with correspondence promptly and with the aim of providing clear, accurate and timely responses.
National Asset Management Agency (NAMA)
NAMA has established a Communications function whose responsibility is to manage external communications with stakeholders and with the press to ensure that the Agency acts as transparently as possible, within the parameters of its legal obligations. Processes for receiving, reviewing, and responding to general public queries have been established as well as processes for handling and responding to Parliamentary Questions, Oireachtas queries and queries from members of Local Authorities. The NAMA Communications Team has overall responsibility for providing information to and responding to follow up queries from members of Local Authorities. Queries from members of Local Authorities are typically responded to on the day received or within 48 hours. If a substantive response is to take longer, an acknowledgement email is issued with an estimated timeframe for the final response and usually within 5 working days. The NAMA CEO and/or Chief Strategy and Transformation Officer oversee and approve responses to members of Local Authorities.
Home Building Finance Ireland (HBFI)
In accordance with HBFI’s Customer Charter (published on its website), HBFI aims to provide an initial response to calls within 24 hours and to respond promptly to all requests from stakeholders
Investor Compensation Company (ICCL)
The ICCL does not maintain a unique standard or service-level target for responding to correspondence from members of local authorities. Instead, ICCL applies a Customer Charter which sets a standard of acknowledging all written correspondence within 10 working days and providing a substantive response, where necessary, within 20 working days. ICCL maintains a programme of internal compliance review with its policies and procedures. The ICCL is not aware of any failure to meet these timelines for responding to the correspondence of an elected official.
Irish Financial Services Appeals Tribunal (IFSAT)
In respect of Service Level Targets, although IFSAT has no employees, and has never received any correspondence from local authorities, the Tribunal has general service-level targets in terms of responding to correspondence and aims to reply to all queries promptly. To date no issues have arisen in respect of delays or failures to respond to correspondence from elected members.
Office of the Revenue Commissioners
Revenue has advised that it has a published Customer Charter, which sets expectations for timeliness, fairness, and quality across all customer interactions, including written correspondence. These expectations cover acknowledgements, substantive responses, clarity of communication, and accessibility.
Customer correspondence received by Revenue, including correspondence received from elected members of local authorities is handled in line with the Customer Charter and in accordance with data protection requirements.
Revenue continuously reviews service performance and customer feedback, including call handling statistics, appointment availability, complaints and compliments, and engagement with representative bodies. Where issues are identified, Revenue adjusts resourcing endeavouring to improve processes and access, including at peak service periods.
Tax Appeals Commission
The Tax Appeals Commission advises that it does not receive correspondence from members of local authorities due to the nature of its work. Regarding standards or service-level targets, the Tax Appeals Commission provides key performance and equality metrics to the Department of Public Expenditure, Infrastructure, Public Service Reform and Digitalisation on an annual basis. The Tax Appeals Commission would respond promptly to any correspondence received from a local authority.
Irish Fiscal Advisory Council
The Irish Fiscal Advisory Council (the Fiscal Council) was established by and its mandate set out in Part 3 of the Fiscal Responsibility Act 2012 , expanded by Section 3 of the Ministers and Secretariats (Amendment) Act 2013.
The Fiscal Council has not set out specific standards or service-level targets in respect of responding to correspondence from members of local authorities. However, it has set out in its Strategic Plan to 'Respond in a timely manner to all queries in relation to its activities'.
Financial Service Pensions Ombudsman (FSPO)
The FSPO advise that it aligns to, the Protocol for the Provision of Information to Members of the Oireachtas by State Bodies under the aegis of Government Departments/Offices, with regards to responding to members of local authorities and compliance of the Protocol is monitored.
Credit Review Office
Credit Review does not have a specific standard for responding to correspondence from local authorities.
However, its Client Charter states it is committed to:
• Return telephone calls / telephone messages within one working day
• Acknowledging written correspondence within 3 working days of receipt
Also, annual performance measurement KPI’s state the following under service quality:
• < 4 written complaints received annually,
• 0 Upheld Financial Services & Pensions Ombudsman Complaints.
Office of the Comptroller and Auditor General
The Office of the Comptroller and Auditor General does not have standards or service-level targets for responding to correspondence from members of local authorities. It is rare for the Office to receive such correspondence.
828. Deputy Tom Brabazon asked the Tánaiste and Minister for Finance if his Department will provide medical exemption for VAT for the athletic rehab therapy sector. [74385/25]
View answerI am advised by Revenue that the VAT rating of goods and services is subject to the requirements of the EU VAT Directive with which Irish VAT law is obliged to comply. Under Irish VAT legislation, professional medical care services supplied by recognised medical professionals who are registered on a statutory register in the State are generally exempt from VAT.
The Department of Health is responsible for the legislation governing medical professionals and statutory registers: examples include the statutory registration of health professionals under the Medical Practitioners Act 2007, the Nurses and Midwives Act 2011, and the Health and Social Care Professionals Act 2005. I understand that athletic therapists within the athletic rehab therapy sector are not a designated profession within the meaning of section 3 of the Health and Social Care Professionals Act 2005 and, therefore, there is no corresponding statutory register.
Under VAT law, where a medical service is supplied by a person who is not registered in accordance with Department of Health legislation, the supply of the service is liable to VAT at the reduced rate, which is currently 13.5%.
829. Deputy Grace Boland asked the Tánaiste and Minister for Finance the office rental costs per annum for staff in his Department and for each agency or organisation under his remit, in each of the years between 2015 and 2025 inclusive, in tabular form; and if he will make a statement on the matter. [74448/25]
View answerDepartment of Finance response
I wish to advise the Deputy that my Department is provided with accommodation by the OPW and does not have a requirement to rent properties.
The following information has been provided by the Bodies under the Aegis of the Department.
Irish Bank Resolution Corporation (IBRC)
|
2015 € |
2016 € |
2017 € |
2018 € |
2019 € |
2020 € |
2021 € |
2022 € |
2023 € |
2024 € |
2025 € |
|
1,292,807 |
976,706.42 |
940,728.60 |
705,546.45 |
267,645.54 |
263,765.83 |
243,096.11 |
0 |
0 |
0 |
0 |
Note: Office rental costs (including VAT excluding service charges and rates). IBRC exited its last remaining leased office premises in December 2021.
Revenue
All Revenue buildings are provided by the OPW and the OPW is responsible for paying any building/ground rents that apply.
Investor Compensation Company
|
2015 € |
2016 € |
2017 € |
2018 € |
2019 € |
2020 € |
2021 € |
2022 € |
2023 € |
2024 € |
2025 € |
|
44,494 |
79,683 |
110,000 |
110,000 |
110,000 |
110,000 |
110,000 |
118,333 |
130,000 |
130,000 |
130,000 |
Credit Review Office
Credit Review pay a service charge to Enterprise Ireland (EI), which covers accommodation, IT services, and overheads etc. The annual rental cost is approximately €47,000 per annum.
Irish Fiscal Advisory Council
The Fiscal Advisory Council offices are located in the Economic & Social Research Institute (ESRI) building. In the period 2015-2018, the ESRI charge was based on a % of overheads so an actual rent per square foot did not apply. Since 2019, the Fiscal Council has a shared service agreement (SSA) in place with the ESRI. Under this agreement, the ESRI provides office accommodation and building services on a pro rata basis and support services relating primarily to accounts, IT, and other corporate services. The proportion of the SSA in respect of office accommodation is outlined in the table below:
|
2015 € |
2016 € |
2017 € |
2018 € |
2019 € |
2020 € |
2021 € |
2022 € |
2023 € |
2024 € |
2025 € |
|
0 |
0 |
0 |
0 |
83,108.64 |
83,108.64 |
79,807.01 |
69,902.13 |
69,902.13 |
69,902.13 |
69,902.13 |
Irish Financial Services Appeals Tribunal
|
2015 € |
2016 € |
2017 € |
2018 € |
2019 € |
2020 € |
2021 € |
2022 € |
2023 € |
2024 € |
2025 € |
|
0 |
2,800 |
22,500 |
23,500 |
23,500 |
25,000 |
25,000 |
25,000 |
25,000 |
25,000 |
25,000 |
Note: IFSAT occupied an office leased from the OPW by the Residential Institutions Redress Review Committee until November 2016.
Credit Union Restructuring Board (ReBo)
|
2015 € |
2016 € |
2017 € |
2018 € |
2019 € |
2020 € |
2021 € |
2022 € |
2023 € |
2024 € |
2025 € |
|
142,728 |
133,045 |
63,871 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
Note:
• ReBo paid rental costs to the Law Reform Commission from 2015 to 2017.
• The Law Reform Commission is a Body under the Aegis of the Office of the Attorney General.
• ReBo has been operationally wound down since July 2017, and the ReBo Dissolution Act 2020 is awaiting commencement.
Financial Services Pensions Ombudsman
|
2015 € |
2016 € |
2017 € |
2018 € |
2019 € |
2020 € |
2021 € |
2022 € |
2023 € |
2024 € |
2025 € |
|
254,246 |
267,188 |
283,723 |
264,978 |
340,190 |
411,939 |
464,435 |
464,435 |
672,391 |
521,066 |
TBD |
Note: 2025 end of year figures have not yet been finalised.
Office of the Comptroller and Auditor General
The Office of the Comptroller and Auditor General is provided with accommodation by the Office of Public Works and does not directly pay for this accommodation.
Central Bank
|
2016 € |
2017 € |
2018 € |
2019 € |
2020 € |
2021 € |
2022 € |
2023 € |
2024 € |
2025 € |
|
3,049,272 |
1,622,315 |
489,217 |
473,514 |
482,561 |
140,160 |
68,831 |
0 |
16,294 |
20,325 |
National Asset Management Agency
|
2015 € |
2016 € |
2017 € |
2018 € |
2019 € |
2020 € |
2021 € |
2022 € |
2023 € |
2024 € |
2025 € |
|
2.25m |
2.44m |
2.44m |
2.44m |
2.38m |
0.35m |
0 |
0 |
0 |
0 |
0 |
•
• Since 2019, NAMA is included in the office rental costs lease provided by the NTMA.
Credit Union Advisory Committee (CUAC)
CUAC are an advisory committee to the Minister set out in the Credit Union Act 1997. CUAC generally meet once a month in the Department’s offices. There are no rental costs for CUAC.
Finally, it was not possible for the NTMA to respond to the information request in the time available and therefore I will provide the information in respect of the National Treasury Management Agency, the Home Building Finance Ireland and the Strategic Banking Corporation of Ireland to the Deputy in line with Standing Orders.
830. Deputy Paul Lawless asked the Tánaiste and Minister for Finance if he will direct the Central Bank to issue guidance requiring insurers to recognise documented foreign no-claims bonuses, given that some insurers already accept them; and whether he will ensure consistency across the industry; and if he will make a statement on the matter. [74535/25]
View answer831. Deputy Paul Lawless asked the Tánaiste and Minister for Finance his views on whether the refusal of insurers to honour foreign driving histories unfairly penalises returning emigrants and undermines Government policy to attract skilled workers home; the steps he will take to address this; and if he will make a statement on the matter. [74536/25]
View answerI propose to take Questions Nos. 830 and 831 together.
As Tánaiste and Minister for Finance, I have policy responsibility for the development of the legal framework governing financial services regulation. While this includes the regulation of the insurance sector, certain regulations relating to motor insurance fall under the responsibility of Minister O'Brien as Minister for Transport. In this context, I am advised that Minister O’Brien and his Department are currently drafting regulations that will prohibit insurers from discriminating against policy holders who present a claims history statement issued in another Member State of the EU.
Furthermore, Insurance Ireland (the industry body for insurers in Ireland) has confirmed that their members will take overseas driving experience into account as long as the driver can provide proof of claims-free driving experience abroad. In general, my officials understand that motor insurers will take no claims history into account from the EEA, the UK, Switzerland, Australia, New Zealand, Japan, Canada, South Africa, and the USA.
Some insurers may accept no claims history from other countries, however, in such circumstances the provision of insurance cover is ultimately a commercial matter for insurance companies and is based on an actuarial assessment of the risks they are willing to accept and adequate provisioning to meet those risks. These are considered by insurance companies on a case-by-case basis. The provision and calculation of a premium is based on several rating factors, including claims history, and these factors determine the final premium issued from an insurance company.
With regard to issuing guidance to the Central Bank of Ireland, it is important to note that the independence of the Central Bank of Ireland is provided for in Section 6(1)(A) of the Central Bank Act 1942, as amended. It is also enshrined in European statute by the Rome Treaty and the ESCB Statute. This independence is vital to the Bank effectively performing its function. As such, the Central Bank is completely independent in the performance of its supervisory, enforcement, and consumer protection functions.
It should be noted that Brokers Ireland, the representative body for insurance brokers in Ireland, have access to a wide range of providers and products and can offer advice for customers in sourcing cover. They can be reached at 01-661-3067. Additionally, Insurance Ireland operate an Insurance Information Service for those who have queries, complaints or difficulties in relation to obtaining insurance, which can be accessed at feedback@insuranceireland.eu or by telephone number 01-676-1820.
832. Deputy Naoise Ó Muirí asked the Tánaiste and Minister for Finance the payroll cost of his Department and of each organisation or agency under its remit individually, in 2015 to 2025, by year, in tabular form. [74626/25]
View answerThis PQ has been withdrawn by the Deputy.
833. Deputy Pat Buckley asked the Tánaiste and Minister for Finance to reduce income tax for working families with children under five, given the unique financial pressure during these early years; and if he will make a statement on the matter. [74829/25]
View answerBudget 2026 was designed to boost our economic resilience and to support workers and growth in their income by investing in jobs and in their future.
In addition, with the substantial personal income tax packages implemented over the last four years, the previous Government made significant progress on increasing the entry point to income tax for all income earners and increasing the point at which the higher rate of income tax takes effect.
Over recent years, the previous Government provided substantial income tax packages to support workers, including working families with young children.
Over the lifetime of the previous Government, the main tax credits increased from €1,650 to €2,000 representing an increase of €350 or 21.2 per cent. The standard rate cut-off point was increased from €35,300 to €44,000 representing an increase of €8,700 or 24.6 per cent.
The income tax measures implemented over the period of the last Government are expected to be in line with wage growth (wages per head of 21.6 per cent).
In regard to USC, over the lifetime of the previous Government the USC ceiling of the band for the 2 per cent rate was increased by €6,898 from €20,484 to €27,382 in line with the increases to the National Minimum Wage.
Furthermore, there was a significant reduction in the middle rate charge from 4.5 per cent to 3 per cent.
Broadly, the income tax measures implemented over the period of the last Government are expected to be in line with wage growth.
As the Deputy will be aware the most recent Budget provided a range of support to individuals, families and businesses. In particular, the Rent Tax Credit, introduced in Budget 2023, has proven to be a very meaningful support for renters. The credit is being extended for a further three years to the end of 2028.
The ceiling of the second USC rate band is being increased by €1,318, from €27,382 to €28,700. This will ensure that a full-time worker on the minimum wage who benefits from the increase in the hourly minimum wage rate from €13.50 to €14.15 will remain outside the highest rates of USC, while also providing a modest benefit to all workers whose income is above that amount.
The 9 per cent VAT on gas and electricity bills is being extended until the 31 December 2030, recognising that energy prices remain high and to help alleviate energy cost pressures for households.
The VAT rate on food and catering businesses and for hairdressing services is being reduced to 9 per cent in line with the commitment in the Programme for Government to further support businesses and help them to retain jobs.
A temporary 9 per cent rate of VAT on the supply and construction of apartments and apartment blocks has been introduced as part of the Government’s social policy, in order to stimulate the development of apartments, which are high-density homes.
All of these measures will have a positive impact.
As Deputy will be aware, this is the first of five Budgets to be delivered by this Government, and the Government remains committed and will stand by the Programme for Government commitment to make progressive changes to personal income tax, if the economy remains strong.
