Dáil Éireann Debate, Thursday - 22 January 2026
325. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance to provide details contained in table 11 of returns (details supplied) excluding all aircraft leasing companies; and if he will make a statement on the matter. [5253/26]
View answer326. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance to provide additional information in relation to the growing negative VAT yield of special purpose vehicles contained in table 11 (details supplied); and if he will make a statement on the matter. [5254/26]
View answerI propose to take Questions Nos. 325 and 326 together.
I am advised by Revenue that a Section 110 company is an Irish resident special purpose vehicle that holds and/or manages “qualifying assets”. These assets may include aircraft. Table 11 in the Corporation Tax statistical report includes a number of aircraft leasing companies, as they are also classified as Section 110 companies.
In respect of your query in Dail Question No. 325 (Ref: 5253/26), Table 1 contains the corporation tax, employment taxes and VAT for the Section 110 companies included in Table 11 of the published report which are not aircraft leasing companies, for the years 2023 and 2024. These are the years which are available at this time.
Table 1: Gross and Net Receipts of Section 110 Companies (excluding Aircraft Leasing Section 110 Companies)
|
Year |
Number of Companies |
Gross CT Receipts: €M |
% of Gross Receipts
|
Net CT Receipts: €M |
% of Net Receipts |
Employment Taxes: €M |
VAT Receipts: €M |
|
2023 |
1,988 |
139 |
0.5% |
119 |
0.5% |
9.6 |
-4.0 |
|
2024 |
2,061 |
89 |
0.2% |
71 |
0.2% |
10.4 |
-6.8 |
In relation to your related query in Dail Question 326 (Ref: 5254/26), the VAT figures in Table 11 of the published report, I am advised by Revenue that the nature of the activity the qualifying company is engaged in will determine the VAT treatment. Qualifying companies are generally engaged in financial type services which are in the main exempt under paragraph 6(1) of Schedule 1 of the VATCA as amended. Where the qualifying company is engaged in an exempt activity, the services it supplies will be exempt from VAT but it is still obliged to self-account for VAT on the services it receives from abroad. Some of the costs incurred will be exempt (such as management fees) but other services such as legal or consultancy fees will be subject to VAT and the qualifying company will be obliged to self-account for the VAT arising under the reverse charge mechanism.
Where a qualifying company is engaged in an exempt activity, it will generally not be entitled to deductibility. It will only be entitled to recovery on its inputs where it has qualifying activities. Section 59 of the VATCA 2010 defines qualifying activities and it includes certain exempt services if supplied from Ireland to customers outside the EU. Such supplies will give rise to a right to recover VAT incurred on costs associated with those supplies.
