Written Answers Nos. 239-258
239. Deputy Pádraig Rice asked the Minister for Transport his views on a recent report by the National Transport Authority which suggests that it will be at least 2028 before contactless payments are available on rail and bus services; the timeline he is working towards on implementing the programme for Government commitment to introduce contactless payments on all public transport; and if he will make a statement on the matter. [13243/25]
Amharc ar fhreagraAs Minister for Transport, I have responsibility for policy and overall funding in relation to public transport. The National Transport Authority (NTA) has responsibility for the planning and development of public transport infrastructure, including ticketing and technology projects.
The NTA's Next Generation Ticketing project is to provide for an upgraded ticketing system to facilitate a variety of payment methods on public transport services, including bus services. Fundamental to this project is a transition to an 'Account Based Ticketing' scheme incorporating mobile and card-based payments.
Following a competitive procurement process, the NTA awarded, in April 2024, an overall framework contract for the design, supply, installation and operation of a new multi-modal ticketing system to a Spanish information technology company - Indra Sistemas S.A. - who have designed, installed and operated similar systems internationally.
In light of the NTA's responsibility in this area, I have forwarded the Deputy's question to the NTA for direct reply. Please contact my private office if you do not receive a response within ten working days.
A referred reply was forwarded to the Deputy under Standing Orders.
240. Deputy Pádraig Rice asked the Minister for Transport if he plans to provide funding to the 1951 CIÉ superannuation pension scheme so that members can receive an increase in payments, given that no increases have been made since 2008; and if he will make a statement on the matter. [13249/25]
Amharc ar fhreagraFrom the outset I would like to clarify that I, as Minister for Transport, have responsibility for policy and overall funding in relation to public transport. However, issues in relation to CIÉ pension schemes are primarily a matter for the trustees of the pension schemes, the CIÉ, Group and their employees. As a commercial semi-state body CIÉ are responsible for the provision of pension schemes for their employees, this is consistent with the pension arrangements of semi-state bodies.
That being said I am acutely aware of concerns raised by the members of both CIÉ pension schemes, regarding the lack of pension increases since 2008, especially given the higher cost of living that many are facing.
My Department is engaged with financial advisors at NewERA, the Pensions Authority, and the Department of Public Expenditure, Infrastructure, Public Services, Reform and Digitalisation on the matter of bringing CIÉ pensions onto a more stable footing for the benefit of active, and retired scheme members.
Concerning pension increases for CIÉ pensioners, I understand that an increase for pensioners would only be possible when the Schemes are capable of sustaining such increases. Furthermore, any such proposal would be dependent on the advice of the Scheme Actuary at the time an increase is proposed, and is done in agreement with the Trustees of the Schemes.
Decisions regarding pension increases are ultimately a matter for the CIÉ Board as informed by actuarial advice and is subject to requirements imposed by statute and scheme rules. Accordingly, I have referred the aspect of Deputy's question related to an increase in pension payments for members to CIÉ for direct reply. Please advise my private office if you do not receive a reply within ten working days.
241. Deputy Matt Carthy asked the Minister for Transport if his Department, or any agency under his Department’s remit, have, since 1 November 2024, entered any contract in respect of a hotel (details supplied) or have had any discussions, or received any offers, in respect of using this premises for any reason; the details of same; and if he will make a statement on the matter. [13288/25]
Amharc ar fhreagraFollowing consultation with my officials, I wish to confirm for the Deputy that my Department has had no engagement with the Hotel referred to in his question during the time period specified.
Noting the relevance of the Deputy's question to the Agencies under the remit of my Department, I have referred his question to them for a direct reply. Please advise my private office if you do not receive a response within 10 working days.
242. Deputy Pa Daly asked the Minister for Finance if he will report on taxi licences for a company (details supplied); if the company demonstrated that it was tax compliant as part of this process; if VAT was paid, a factor required for qualification; and if he will make a statement on the matter. [13011/25]
Amharc ar fhreagra245. Deputy Pa Daly asked the Minister for Finance if he will report on VAT as it pertains to taxi drivers, specifically drivers in a company (details supplied); how the reverse VAT obligation will apply; if it will apply from 2025 onwards; and if he will make a statement on the matter. [13010/25]
Amharc ar fhreagraI propose to take Questions Nos. 242 and 245 together.
The Deputy will appreciate that Revenue is bound by the confidentiality provisions in Section 851A of the Taxes Consolidation Act from commenting on the taxation position of specific taxpayers.
Revenue operates a self-assessment system for VAT and therefore the application of VAT on services is primarily a matter for the company or person providing those services. Revenue provides guidance in relation to the issue of VAT on services on its website, www.revenue.ie, and in the form of various Tax and Duty manuals. Revenue will also provide specific advice or guidance to taxpayers that seek VAT advice on the services that they are providing through contact with the relevant Revenue branch or through its Revenue Technical Service.
In relation to the specific services referred to by the Deputy, Revenue published a Tax and Duty Manual of the VAT Treatment relevant to Taxi drivers in February 2025 and this can be accessed on the Revenue website. This Manual explains, with the use of practical examples relevant to their business, how the various existing VAT rules apply to taxi drivers. This manual does not introduce any new rules or reporting requirements for taxi drivers.
243. Deputy Pearse Doherty asked the Minister for Finance the details of all auditing work done by the Comptroller and Auditor General for public bodies for which the Comptroller and Auditor General is remunerated; and if he will make a statement on the matter. [13174/25]
Amharc ar fhreagraThe function/office of C&AG is established under Article 33 of Bunreacht na hÉireann. The holder of the office is required (inter alia) to audit the accounts of all bodies or funds operated by or under the authority of Dáil Éireann. The list of such bodies or funds changes from time to time, in line with legislation on the formation or cessation of public bodies.
The C&AG is currently responsible for the audit of the following financial statements and accounts (with periods of account ending during 2024):
• 45 appropriation accounts of vote-funded departments and offices
• Finance accounts and 8 other Central Fund related accounts
• 18 other fund accounts, including statutory funds held separately from the Central Fund (e.g. Social Insurance Fund; National Training Fund; Local Government Fund)
• Financial statements of HSE and 28 other health agencies
• Financial statements of 17 third level education bodies
• Financial statements of 16 education and training boards
• Financial statements of 7 North/South bodies (audited jointly/in cooperation with the C&AG for Northern Ireland)
• Financial statements of 149 other non-commercial state bodies.
A full listing of individual bodies and funds is available on the website of the Office of the Comptroller and Auditor General.
The C&AG is remunerated from the Central Fund of the Exchequer, in line with legislation. Bunreacht na hÉireann prohibits the holder of the office from holding any other position of emolument.
The Office of the Comptroller and Auditor General (OCAG) charges audit fees in respect of the annual audits of most non-vote financial statements and accounts. Audit fees are received by the OCAG and applied as appropriations-in-aid of the OCAG’s Vote (Vote 8).
The C&AG is an independent Constitutional officer, and further questions regarding his work should be addressed directly to his Office.
244. Deputy Aidan Farrelly asked the Minister for Finance the total number of copper communication lines within his Department currently in active operation and for which his Department is paying for on a monthly basis inclusive of ISDN, PTSN and copper-based lease lines; and if he will make a statement on the matter. [12985/25]
Amharc ar fhreagraI wish to advise the Deputy that there are 36 active copper communication lines inclusive of ISDN, PSTN, copper-based and lease lines across my department and the Department of Public Expenditure, National Development Delivery Plan and Reform (as part of a shared services arrangement whereby my Department pays the monthly costs). My Department keeps these requirements under review.
246. Deputy Aidan Farrelly asked the Minister for Finance the date on which he last received a status report from the Ireland Strategic Investment Fund in respect of a campus (details supplied). [13025/25]
Amharc ar fhreagraI refer the Deputy to the responses given by the then Ministers for Finance under Parliamentary Questions 120 answered on 18 June 2024 and 122 answered on 4 July 2024. I understand that the position has not changed since these substantive replies issued. See links below.
www.oireachtas.ie/en/debates/question/2024-07-04/122/#pq_122
www.oireachtas.ie/en/debates/question/2024-06-18/120/
247. Deputy Alan Kelly asked the Minister for Finance when he expects the Revenue Commissioners to receive their new customs cutter vessels; and the number of Revenue Commissioners staff, by grade, that have been trained to navigate the new vessels. [13131/25]
Amharc ar fhreagraI am advised by Revenue that, following a procurement process, a contract for the delivery of a new Revenue Customs Cutter was signed with AuxNaval in August 2023 and is expected to come into service in September 2025. The new Cutter will replace RCC Suirbhéir which is in service since 2004 and is approaching the end of its service life. The contract includes an option for a second Cutter, which could be a replacement for RCC Faire in time.
The new Cutter, along with RCC Faire, will be operated by Revenue’s Maritime Unit (RMU), which has responsibility for patrolling Ireland's 3,173 kilometres of coastline.
The RMU has sanction for 29 officers with the necessary skills and qualifications for sea-going duties, broken down as follows:
|
Higher Executive Officer |
4 |
|
Executive Officer |
9 |
|
Clerical Officer |
16 |
I am aware that Revenue has recently completed an open competition for Clerical Officers and an internal competition for Executive Officers in the RMU and is in the process of recruiting from those panels. All new recruits will undertake an extensive training programme to equip them to fulfil their duties as maritime Customs Officers.
248. Deputy Pearse Doherty asked the Minister for Finance to provide a list of all late payment fees imposed by the Revenue Commissioners; the amount collected under each heading each year since 2016, in tabular form; and if he will make a statement on the matter. [13155/25]
Amharc ar fhreagraI am advised by Revenue that it strongly encourages timely compliance and engagement by taxpayers towards paying the right amount of tax at the right time and meeting their return filing obligations. By doing so, taxpayers avoid any exposure to penalties or interest for late payment.
Collection of interest by Revenue is a key element in reflecting the value of money forgone by the Exchequer where a taxpayer does not pay what is due on time and is also vital in supporting the efforts of the vast majority of taxpayers who are voluntarily and fully compliant. Revenue has confirmed that the levying of interest on late payment of tax is a statutory charge that must be factored into any phased payment agreement or debt collection/enforcement action.
Details of the interest and penalties collected by Revenue for the years 2016 to 2024 (including the interest and penalties collected as part of Revenue’s risk management intervention and late filing/non-filing programmes) are set out in the tables below.
Table 1- Interest Collected by Revenue
|
- |
2016 €m |
2017 €m |
2018 €m |
2019 €m |
2020 €m |
2021 €m |
2022 €m |
2023 €m |
2024 €m |
|
PAYE/PRSI |
20.93 |
9.76 |
17.94 |
22.91 |
11.96 |
19.81 |
29.78 |
16.46 |
18.74 |
|
VAT |
15.10 |
16.34 |
18.79 |
20.02 |
10.10 |
12.23 |
14.35 |
18.05 |
20.92 |
|
INCOME TAX (Self-Employed) |
29.28 |
33.37 |
37.43 |
26.17 |
18.96 |
11.47 |
16.27 |
21.38 |
31.72 |
|
CORPORATION TAX |
11.63 |
10.12 |
18.23 |
15.45 |
56.89 |
152.94 |
74.45 |
89.52 |
42.85 |
|
CAPITAL GAINS TAX |
5.86 |
4.93 |
6.61 |
9.90 |
4.44 |
3.86 |
4.35 |
8.20 |
6.67 |
|
RELEVANT CONTRACTS TAX |
0.52 |
0.27 |
0.40 |
0.19 |
0.11 |
0.02 |
0.23 |
0.44 |
0.47 |
|
DIVIDEND WITHOLDING TAX |
0.11 |
0.28 |
0.11 |
0.60 |
0.41 |
7.79 |
0.16 |
-0.19 |
0.05 |
|
RELEVANT TAX ON SHARE OPTION |
0.74 |
0.78 |
0.32 |
0.50 |
0.19 |
0.38 |
0.62 |
0.56 |
0.70 |
|
STAMP DUTY |
3.51 |
2.62 |
1.99 |
1.84 |
1.89 |
2.61 |
1.78 |
2.44 |
2.40 |
|
CAPITAL ACQUISITIONS TAX |
3.07 |
2.45 |
2.33 |
2.59 |
2.10 |
2.45 |
2.51 |
2.19 |
2.90 |
|
LOCAL PROPERTY TAX |
0.04 |
0.08 |
0.14 |
1.17 |
1.76 |
3.16 |
4.52 |
5.25 |
5.79 |
|
OTHER |
0.43 |
1.47 |
1.65 |
0.59 |
1.90 |
2.60 |
3.89 |
2.87 |
8.90 |
|
Total |
91.22 |
82.47 |
105.94 |
101.93 |
110.71 |
219.32 |
152.91 |
167.17 |
142.11 |
Table 2 – Penalties Collected by Revenue
|
- |
2016 €m |
2017 €m |
2018 €m |
2019 €m |
2020 €m |
2021 €m |
2022 €m |
2023 €m |
2024 €m |
|
PAYE/PRSI |
5.54 |
4.66 |
6.19 |
4.01 |
5.66 |
0.96 |
0.83 |
2.12 |
5.01 |
|
VAT |
4.57 |
5.11 |
8.18 |
5.98 |
4.03 |
2.30 |
4.02 |
3.03 |
4.71 |
|
INCOME TAX (Self-Employed) |
5.03 |
4.66 |
5.32 |
4.36 |
3.02 |
2.05 |
3.46 |
2.60 |
4.20 |
|
CORPORATION TAX |
2.06 |
2.17 |
2.33 |
0.88 |
1.52 |
1.85 |
1.67 |
1.92 |
2.05 |
|
CAPITAL GAINS TAX |
0.75 |
0.52 |
0.97 |
0.94 |
0.66 |
1.43 |
1.37 |
1.12 |
0.80 |
|
RELEVANT CONTRACTS TAX |
2.68 |
2.92 |
3.09 |
3.30 |
1.70 |
1.60 |
2.96 |
2.87 |
4.46 |
|
DIVIDEND WITHOLDING TAX |
0.01 |
0.01 |
0.01 |
0.01 |
0.00 |
1.91 |
0.00 |
0.00 |
0.01 |
|
RELEVANT TAX ON SHARE OPTION |
0.03 |
0.03 |
0.05 |
0.00 |
0.00 |
0.00 |
0.01 |
0.10 |
0.10 |
|
STAMP DUTY |
1.27 |
1.57 |
1.46 |
1.40 |
1.27 |
1.46 |
1.68 |
1.69 |
1.59 |
|
CAPITAL ACQUISITIONS TAX |
0.56 |
0.73 |
0.30 |
0.30 |
0.42 |
0.08 |
0.18 |
0.29 |
0.26 |
|
LOCAL PROPERTY TAX |
0.00 |
0.00 |
0.00 |
0.00 |
0.00 |
0.00 |
0.00 |
0.00 |
0.00 |
|
OTHER |
0.11 |
0.29 |
0.29 |
0.46 |
0.64 |
0.35 |
0.71 |
0.20 |
0.79 |
|
Total |
22.61 |
22.67 |
28.19 |
21.64 |
18.92 |
13.99 |
16.89 |
15.94 |
23.98 |
The data on late filing surcharges is not readily available but will be extracted and supplied to the Deputy separately.
249. Deputy Pearse Doherty asked the Minister for Finance to outline the definition used by Irish banks to determine non-performing loans for mortgages; and if he will make a statement on the matter. [13156/25]
Amharc ar fhreagraCredit institutions engaged in mortgage lending in Ireland align their definition of non-performing loans (NPLs) with relevant European banking regulation.
The most relevant legislation is Regulation (EU) 575/2013 (the Capital Requirements Regulation), as amended, where Article 47a defines non-performing exposures (NPE) as those meeting any of the following criteria:
(a) an exposure in respect of which a default is considered to have occurred in accordance with Article 178 of the Regulation, including either where the obligor is deemed unlikely to pay by the institution and/or the obligor is more than 90 days past due on any material credit obligation to the institution;
(b) an exposure which is considered to be impaired in accordance with the applicable accounting framework;
(c) an exposure under probation pursuant to paragraph 7 of the Article, where additional forbearance measures are granted or where the exposure becomes more than 30 days past due;
(d) an exposure in the form of a commitment that, were it drawn down or otherwise used, would likely not be paid back in full without realisation of collateral;
(e) an exposure in form of a financial guarantee that is likely to be called by the guaranteed party, including where the underlying guaranteed exposure meets the criteria to be considered as non-performing.
Other relevant legislation includes EBA Guidelines on management of non-performing and forborne exposures and EBA Guidelines on the application of the definition of default.
Definitions used by credit institutions in Ireland for NPEs and NPLs (the terms are used interchangeably) are therefore largely aligned as follows:
AIB, in their 2024 Annual Report define non-performing loans as follows:
“Loans are identified as non-performing or defaulted by a number of characteristics. The key criteria resulting in a classification of non-performing are:
• Where the Group considers a borrower to be unlikely to pay their loans in full without realisation of collateral, regardless of the existence of any past-due amount; or
• The borrower is 90 days or more past due on any material loan. Day count starts when any material amount of principal, interest or fee has not been paid by a borrower on the due date”.
Bank of Ireland, defines non-performing exposures in their 2024 Annual Report, as:
These are:
• credit-impaired loans which includes loans where the borrower is considered unlikely to pay in full without recourse by the Group to actions such as realising security, and / or loans where the borrower is greater than or equal to 90 days past due and the arrears amount is material; and
• other loans meeting NPE criteria as aligned with regulatory requirements”
PTSB defines non-performing loans in their 2024 Annual Report as:
“Loans which are credit impaired or loans which are classified as defaulted in accordance with the Group’s definition of default. The Group’s definition of default considers objective indicators of default including the 90 days past due criterion, evidence of exercise of concessions or modifications to terms and conditions is designed to be consistent with European Banking Authority (EBA) guidance on the definition of forbearance”.
250. Deputy Pearse Doherty asked the Minister for Finance the total value of property that was exempt from CAT due to the heritage exemption each year since 2016; and if he will make a statement on the matter. [13157/25]
Amharc ar fhreagraUnder sections 77 and 78 of CATCA 2003, CAT gifts and inheritances of pictures, prints, books, manuscripts, works of art, jewellery, scientific collections or other things not held for the purposes of trading may be exempt from CAT where the following conditions are satisfied: (1) the property is of national, scientific, historic or artistic interest, (2) the property is kept permanently in the State, and (3) reasonable facilities for viewing are allowed to members of the public or to recognised bodies or to associations of persons.
The exemption also applies to houses and gardens in the State not held for the purposes of trading in respect of which: (1) on a claim made to Revenue appear to be of national, scientific, historic or artistic interest, (2) reasonable facilities for viewing were allowed to the public during the three-year period prior to the date of the gift or inheritance, and (3) reasonable facilities for viewing are allowed to the public following the gift or inheritance.
Clawback of the exemption may occur in certain circumstances.
I am advised by Revenue that Information in respect of the total value of property that was exempt from CAT due to the heritage exemption each year since 2016 is shown below.
|
Year |
Value €million |
|
2016 |
1.1 |
|
2017 |
1.2 |
|
2018* |
X |
|
2019 |
2 |
|
2020 |
2.5 |
|
2021 |
0.4 |
|
2022 |
3.8 |
|
2023 |
2.3 |
*2018 is redacted in order to protect taxpayer confidentiality
Information for 2024 is not yet available.
251. Deputy Pearse Doherty asked the Minister for Finance the total number of section 110 applications, that is, unique form S.110 submissions each year since 2016; the total number approved; the number approved in each type of transaction classes; the number approved for dealing with each qualifying asset type, in tabular form; and if he will make a statement on the matter. [13158/25]
Amharc ar fhreagra264. Deputy Pearse Doherty asked the Minister for Finance the number of section 110 special purpose vehicles in operation each year from 2016 to 2024 and to date in 2025; and if he will make a statement on the matter. [13208/25]
Amharc ar fhreagraI propose to take Questions Nos. 251 and 264 together.
Section 110 of the Taxes Consolidation Act 1997 sets out a regime for the taxation of special purpose companies set up to securitise assets. The tax provisions are intended to create a tax neutral regime for bona-fide securitisation and structured finance purposes. The section 110 regime enables noteholders to invest through one structured vehicle, without giving rise to an additional layer of tax as compared to a direct investment in the underlying assets.
Securitisation allows banks to raise capital and to share risk and, by providing a repackaging and resale market for corporate debt, it lowers the cost of debt financing. It is accepted that having the option for more diversified sources of financing is good for investment and business. It is also important for financial stability in the economy, as the ability to securitise loan books plays an important role in allowing banks to meet their capital requirement obligations and to continue lending to businesses and individuals.
To come within the section 110 regime, a company must be a “qualifying company” and fulfil a number of conditions, including in relation to the type of assets that the company can hold and in turn the nature of activities that may be undertaken by the company. To be a qualifying company, section 110 TCA 1997 requires (among other things) that:
The company is tax resident in Ireland and carries on the business of holding or managing "qualifying assets". Generally speaking, qualifying assets are assets in respect of which securitisation transactions are undertaken. This includes a broad range of financial and other assets including shares, bonds, derivatives, loans, deposits, commodities, plant and machinery and invoices and other types of receivable.
The value of qualifying assets is at least €10 million at the time they were acquired by the section 110 company.
Apart from the holding or managing of the qualifying assets, the company is not carrying on any other activities.
In order to avail of this regime, a company must, amongst other conditions, notify an 'authorised officer' in Revenue that:
• it is, or intends to be, a 'qualifying company'
and
• it meets the criteria of paragraphs (a) to (e) of the definition of 'qualifying company' Section 110(1) of the TCA, 1997.
I am informed by Revenue that the below table sets out the number of notifications received by the authorised officer that are regarded as meeting the criteria to be a qualifying company in respect of each of the years since 2016 to 2024, and to date in 2025. The table also sets out the number of qualifying companies that are live as at March 2025. The term “live” refers to qualifying companies where a Form S.110W withdrawal notification has not been received, and/or the company’s tax registration is not ceased and/or the company is not dissolved. I am advised by Revenue that a breakdown by transaction class or qualifying asset type is not available.
|
Year |
Number of Notifications Received* |
Live as at March 2025 |
|
2016 |
480 |
319 |
|
2017 |
387 |
296 |
|
2018 |
483 |
414 |
|
2019 |
540 |
503 |
|
2020 |
364 |
348 |
|
2021 |
589 |
579 |
|
2022 |
393 |
389 |
|
2023 |
415 |
412 |
|
2024 |
521 |
521 |
|
2025 to date |
101 |
101 |
|
Cumulative |
4,273 |
3,882 |
252. Deputy Pearse Doherty asked the Minister for Finance to provide an exhaustive list of the State’s double taxation treaties; and if he will make a statement on the matter. [13159/25]
Amharc ar fhreagraTax treaties allow for the smooth and regulated taxation of international business and investment activities. Ireland’s longstanding tax treaty policy has been to expand, maintain, and enhance its network to remove barriers and facilitate trade and investment opportunities between Ireland and partner jurisdictions. They provide greater certainty and fairness for taxpayers regarding their tax obligations in foreign jurisdictions and are key to the prevention of double taxation. Furthermore, they provide for dispute resolution mechanisms and exchange of taxpayer information to enhance tax transparency.
In June 2022, the Department of Finance published Ireland’s tax treaty policy statement. The published policy statement sets out the broad parameters of Ireland’s policy based on two central themes – consideration for Ireland’s economy and trade and recognition that different considerations apply to tax treaties with developing countries. The statement identifies key priority areas for the coming years to ensure the continued expansion and enhancement of our tax treaty network.
Ireland’s tax treaty network is extensive; Ireland has signed 78 tax treaties, of which 75 are currently in effect. Ireland has tax treaties with all EU Member States and all OECD member countries, bar the two newest members (Colombia and Costa Rica ).
The table at the following link sets out the full list of treaties as requested:
253. Deputy Pearse Doherty asked the Minister for Finance further to Parliamentary Question No. 297 of 5 February 2025, if he will consider introducing an exemption to the 1% life insurance levy on people with life-long disabilities, particularly in cases where they rely heavily on compensation awards; and if he will make a statement on the matter. [13161/25]
Amharc ar fhreagraAs was noted in my reply to the Deputy's similar PQ that issued to him on the 5th of February this year,
I am advised by Revenue that section 124B of the Stamp Duties Consolidation Act 1999 provides for a Stamp Duty levy of 1% to be levied in respect of certain life insurance premiums paid to insurers. The levy is payable by the insurers to Revenue on a quarterly basis. It was introduced in 2009.
The levy is applied to the premiums paid under certain classes of life insurance policies to the extent that the risks to which the policies relate are located in the State. These classes are as follows:
• Class I – Life assurance and contracts to pay annuities on human life;
• Class II – Contracts of insurance to provide a sum on marriage or the birth of a child;
• Class III – Class I policies linked to investment funds
• Class IV – Permanent Health Insurance;
• Class V – Tontines, i.e., associations of subscribers which are established to benefit the beneficiaries of a subscriber on the death of that subscriber; and
• Class VI – Capital redemption operations, i.e., in return for a single (or periodic) payment agreed in advance, the policy holder will have a right to a specified sum for a specified period in the future.
Certain premiums are excluded from the levy, namely:
• premiums received in respect of pension business, as defined in section 706 of the Taxes Consolidation Act 1997, and
• premiums received in the course of or by means of reinsurance.
In relation to the 1% levy on certain life insurance premiums, as you may be aware my predecessor as Minister for Finance published the Report of the Funds Sector 2030 (Review) on 22 October 2024.
The Report of the Review is available at: www.gov.ie/en/publication/da341-funds-sector-2030-a-framework-for-open-resilient-and-developing-markets/
Recommendation 23 of the Report includes "Repeal of the 1% life assurance levy".
The Programme for Government "Securing Ireland's Future" published on 23 January 2025 includes a commitment to progress and publish an implementation plan for consideration on the Funds Review recommendations to unlock retail investment and opportunities to grow this sector in Ireland, and I, working with my officials, will consider next steps in this regard over the coming months.
254. Deputy Pearse Doherty asked the Minister for Finance if the Revenue Commissioners have ever declined to approve any pension transfer overseas on the grounds of tax avoidance or any other reason; and if he will make a statement on the matter. [13162/25]
Amharc ar fhreagraRevenue approval is required in advance of transfers to a pension scheme in a country other than the UK or an EU Member State. If the transfer is to a country outside the EU (other than the UK) a transfer may not be made to a country other than the one in which the member is currently employed.
I am advised by Revenue that due to the small number (less than 10) of applications for pension transfers overseas declined in the last three years and Revenue’s obligation to maintain the confidentiality of taxpayer information, specific quantitative information in relation to these applications cannot be provided.
I am advised, however, that where appropriate Revenue has declined to approve pension transfers overseas. The principal basis on which Revenue has refused to approve an application for the transfer of a pension arrangement overseas is that the scheme member was not employed in the country of the proposed transfer.
255. Deputy Pearse Doherty asked the Minister for Finance to set out categories of eligible collateral accepted by the Central Bank of Ireland for commercial banks seeking access to the lending facilities; to clarify if mortgages can be used as collateral by banks seeking to access Central Bank borrowing facilities; and if he will make a statement on the matter. [13172/25]
Amharc ar fhreagraI am informed by the Central Bank of Ireland that the main categories of marketable assets accepted under the Eurosystem's general (permanent) collateral framework are central government securities, corporate bonds, covered bonds, unsecured bank bonds, regional government securities, and asset-backed securities.
For non-marketable assets, the Eurosystem accepts certain types of credit claims (i.e. bank loans) to non-financial corporates, public sector entities (excluding public financial corporations), multilateral development banks and international organisations.
In the case of residential mortgages, the Eurosystem accepts two types of marketable assets under the general (permanent) collateral framework which are backed by pools of residential mortgages. Covered bonds are dual recourse assets issued by credit institutions which are generally secured by a pool of residential mortgages.
Residential mortgage backed securities (RMBS), a specific class of asset-backed securities, are another type of marketable asset accepted by the Eurosystem whereby the notes are backed by pools of residential mortgages. In addition, one non-marketable asset, retail mortgage-backed debt instruments (RMBDs), are also accepted under the general framework but this will be phased out as part of a wider simplification of the Eurosystem's collateral framework.
Aside from the general collateral framework, the Eurosystem has also operated a temporary collateral framework since the global financial crisis, which comprises crisis-related collateral easing measures. The temporary framework consists of assets (e.g. additional credit claims (ACCs)) that do not satisfy all the eligibility criteria of the general framework and were introduced to address the increased collateral needs of counterparties at times of heightened financial stress. ACCs can include pools of mortgages. However, these will be phased out in the coming year.
256. Deputy Pearse Doherty asked the Minister for Finance the details of any secondments from consulting firms to his Department since 2020; the consulting firm involved; the purpose of the secondment; the durations of the secondments; who paid the salary of the individual seconded; and if he will make a statement on the matter. [13182/25]
Amharc ar fhreagraI wish to inform the Deputy that there were no secondments from consulting firms to my Department in the period from 2020 to present.
257. Deputy Pearse Doherty asked the Minister for Finance the total shareholding in AIB each year since 2017, detailing each year shares were sold, the amount, share price and total income; and if he will make a statement on the matter. [13195/25]
Amharc ar fhreagraThe State invested €20.8bn in AIB between 2009 and 2011. The State has made good progress in reducing its shareholding in AIB from 71.12% at the beginning of 2022 to just under 12% today while recovering c. €17.9m as part of that process. The State's remaining shareholding in AIB (as at close of business on 17/3/2025) is worth approximately €1.87bn.
I have outlined below the State's shareholding in AIB at each year-end since 2017:
2017: 71.12%
2018: 71.12%
2019: 71.12%
2020: 71.12%
2021: 71.12%
2022: 57%
2023: 40.8%
2024: 18.8%
I have outlined below details of the various share sales (IPO, share trading plan, share buybacks and accelerated bookbuild transactions) since 2017:
|
Year |
Share Sale |
Number of Shares Sold |
Average Price per Share |
Proceeds |
|
2017 |
IPO |
780,384,606 |
€4.40 |
€3,433.7m |
|
2022 |
Trading Plan (phase 1) |
70,936,735 |
€2.32 |
€164.8m |
|
2022 |
Share Buyback |
28,466,799 |
€2.22 |
€63.2m |
|
2022 |
ABB 1 |
133,600,000 |
€2.28 |
€304.8m |
|
2022 |
Trading Plan (phase 2) |
42,540,104 |
€2.86 |
€121.5m |
|
2022 |
ABB 2 |
134,000,000 |
€2.96 |
€396.6m |
|
2023 |
Trading Plan (phase 3) |
106,010,351 |
€3.89 |
€412.7m |
|
2023 |
Share Buyback |
54,674,819 |
€3.94 |
€215.3m |
|
2023 |
ABB 3 |
132,000,000 |
€3.64 |
€480.5m |
|
2023 |
Trading Plan (phase 4) |
31,278,344 |
€4.22 |
€131.9m |
|
2023 |
ABB |
131,000,000 |
€3.93 |
€514.8m |
|
2024 |
Trading Plan (phase 5) |
129,451,168 |
€4.80 |
€620.7m |
|
2024 |
Share Buyback |
198,233,952 |
€5.04 |
€999m |
|
2024 |
ABB 5 |
121,000,000 |
€4.90 |
€592.9m |
|
2024 |
Trading Plan (phase 6) |
117,055,470 |
€5.37 |
€628.2m |
|
2024 |
Share Buyback |
91,827,364 |
€5.45 |
€500m |
|
2025 |
ABB 6 |
116,450,000 |
€5.60 |
€652.1m |
|
2,418,909,712 |
€10,233m |
Please note that phase 7 of the AIB share trading plan is currently operational and runs until July 2025.
As the Deputy is aware, €29.4bn was invested in AIB, BOI and PTSB over the period 2009 to 2011. To date, c. €27.4bn has been recovered in cash by way of disposals, investment income and liability guarantee fees. The remaining investments in the banks are currently valued at c. €2.37bn (as at close of business on 17/3/2025) meaning the State is just above breakeven on its investment in the three banks on a cash-in/cash-out basis.
The State also holds warrants which were issued by AIB following the IPO of the bank in June 2017 and Department of Finance officials have commenced exploratory discussions with AIB on a buyback of these warrants, while also examining other available options.
258. Deputy Pearse Doherty asked the Minister for Finance if the levels 1 or 2 intervention under the compliance intervention framework has an upper limit on the size of the potential tax liability to avail of this avenue for minimising penalties and avoiding publication on list of defaulters; the maximum level of penalty mitigation allowed under each level of intervention under the compliance intervention framework; and if he will make a statement on the matter. [13196/25]
Amharc ar fhreagraI am advised by Revenue that the intervention levels in its Compliance Intervention Framework enable it to deliver a consistent graduated response to taxpayer behaviour and compliance risk.
Level 1 interventions are aimed at supporting taxpayers by reminding them of their obligations and providing them with the opportunity to correct errors. A Level 1 intervention is only used where Revenue has not already engaged in any detailed examination or review of the matters under consideration. Taxpayers in receipt of a Level 1 compliance intervention may avail of the opportunity to self-correct their tax returns without penalty, if within the relevant time limits, or make an unprompted qualifying disclosure. Penalties will apply to any liability disclosed by way of an unprompted qualifying disclosure. Those penalties range from 3% to 100% depending on the category of default and the disclosure history of the taxpayer. Taxpayers who make an unprompted qualifying disclosure are protected from publication in the quarterly list of tax defaulters and from prosecution in relation to any tax offences identified in the disclosure. There is no limit on the amount of tax default that may be disclosed by way of an unprompted qualifying disclosure.
A Level 1 intervention may identify issues that warrant the initiation of a Level 2 intervention. For example, where a taxpayer makes an unprompted disclosure which is not qualifying, a Level 2 intervention will be initiated. Likewise, where a taxpayer does not respond to a Level 1 intervention, Revenue may proceed to examine the matter as part of a Level 2 intervention. Level 2 interventions are used by Revenue to confront identified compliance risk.
Level 2 interventions are carried out where Revenue has identified a tax risk. In these interventions, taxpayers may no longer avail of self-correction or make an unprompted qualifying disclosure. At the commencement of a Level 2 intervention, a taxpayer may make a prompted qualifying disclosure. Such disclosures face higher penalties, ranging from 10% to 100% depending on the category of default, the disclosure history of the taxpayer and whether the taxpayer cooperates fully with the intervention. A taxpayer who makes a prompted qualifying disclosure is also protected from publication in the quarterly list of tax defaulters and from prosecution in relation to tax offences identified in the disclosure. In cases where a taxpayer has failed to make a prompted qualifying disclosure or makes a disclosure which is not qualifying, penalties on any default identified will range from 15% to 100%. Such taxpayers also face publication in the quarterly list of tax defaulters subject to any default meeting the publication criteria and may also be subject to prosecution in relation to any tax offences identified. There is no limit on the amount of tax default that may be addressed in a Level 2 intervention.
For further information in relation to the Compliance Intervention Framework, the Deputy may wish to consult the Code of Practice for Revenue Compliance Interventions which is available on the Revenue website at: www.revenue.ie/en/tax-professionals/documents/code-of-practice-revenue-compliance-interventions.pdf
