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Wednesday, 26 Nov 2025

Written Answers Nos. 130-149

Tax Code

Ceisteanna (137, 138, 139, 140, 141)

Barry Ward

Ceist:

137. Deputy Barry Ward asked the Tánaiste and Minister for Finance if any review or research has been carried out into the potential cost to the Exchequer of waiving the cost of local property tax for all those in receipt of the state pension; and if he will make a statement on the matter. [66404/25]

Amharc ar fhreagra

Barry Ward

Ceist:

138. Deputy Barry Ward asked the Tánaiste and Minister for Finance if any review or research has been carried out into the potential cost to the Exchequer of waiving the cost of local property tax for all those in receipt of the widows pension; and if he will make a statement on the matter. [66405/25]

Amharc ar fhreagra

Barry Ward

Ceist:

139. Deputy Barry Ward asked the Tánaiste and Minister for Finance his views on the merits of conducting an overall assessment of the existing local property tax scheme to create a more equitable system based on ability to pay rather than property value; and if he will make a statement on the matter. [66406/25]

Amharc ar fhreagra

Barry Ward

Ceist:

140. Deputy Barry Ward asked the Tánaiste and Minister for Finance his views on the merits of waiving the cost of the local property tax for all those in receipt of the widows pension; and if he will make a statement on the matter. [66407/25]

Amharc ar fhreagra

Barry Ward

Ceist:

141. Deputy Barry Ward asked the Tánaiste and Minister for Finance his views on the merits of waiving the cost of the local property tax for all those in receipt of the State pension; and if he will make a statement on the matter. [66408/25]

Amharc ar fhreagra

Freagraí scríofa

I propose to take Questions Nos. 137, 138, 139, 140 and 141 together.

Local Property Tax (LPT) was legislated for in 2012 in the Finance (Local Property Tax) Act 2012. The design of LPT was considered by an interdepartmental group chaired by Dr. Don Thornhill. In 2015, Dr. Thornhill also produced a review of the operation of the LPT. The tax was subject to another review in 2019 by an interdepartmental group chaired by the Department of Finance.

The potential impact of a waiver on LPT for those in receipt of the State Pension or Bereaved Partner’s Pension (formerly known as the Widows Pension) was not examined as part of these reports. I am advised by Revenue that it is not possible to conduct the analysis identified by the Deputy because there is no marker on a LPT return to indicate that the owner is in receipt of a State payment.

Regarding an assessment of the current LPT structure, in advance of revaluation this year, officials in Revenue’s Statistics Branch conducted an extensive modelling and valuation exercise in respect of LPT liable properties. The purpose of this work was to inform policy decisions and to assist with providing guidance to taxpayers on the valuation of their properties ahead of this November. A paper outlining the process was published in September and is available on Revenue’s website: www.revenue.ie/en/corporate/documents/research/property-valuation-technical-paper-2026.pdf.

Revenue collaborated with the Department of Finance in respect of various scenarios and their estimated impacts under the model. This collaboration allowed Department officials to prepare options for Minister Donohoe to consider in respect of revaluation, taking into account the Programme for Government commitment, the impact on property owners and the overall tax yield.

The changes to LPT that have been implemented will ensure that the majority of homeowners remain in the same valuation band and pay between €5-25 in extra LPT for 2026 onwards. This represents the first increase in LPT charges since the introduction of the tax in 2013. Accordingly, Government have agreed it is fair to ask property owners to pay a small amount more going forward, with the result of raising approximately €45 million of additional funding for local services.

Furthermore, Government approved the indexation of the income thresholds for deferral of LPT for 2026-2030, ensuring that the thresholds keep pace with inflation and growth in wages and State payments since 2021.

A small number of properties will move up a band due to significant appreciation in value since 2021. It was not possible to ensure these properties would remain in their current band without consequentially causing many other properties to drop one or more bands. I believe that we have struck an appropriate balance with the charging mechanism for 2026-2030.

On the introduction of the LPT, the Government decided that a liability to the tax should apply to all owners of residential properties with a limited number of exemptions. Limiting the exemptions available allows the rate to be kept low for those liable persons who do not qualify for an exemption. There is no specific exemption from the requirement to pay LPT for property owners in receipt of the State Pension or Bereaved Partner’s Pension under the Finance (Local Property Tax) Act 2012 (as amended), though such persons may be entitled to an exemption on other grounds or may qualify for a deferral subject to meeting the qualifying conditions.

As mentioned, homeowners have the possibility of deferring the charge to LPT in certain circumstances. A qualifying person may opt to defer, or partially defer, payment of the tax. Where a person qualifies for a full deferral, 100% of the liability can be deferred. Where a person qualifies for partial deferral, then 50% of the liability can be deferred. The balance of 50% of the tax must be paid. The deferred tax remains as a charge on the property and must be paid before a sale or transfer can be completed. Interest is charged at 3% per annum on the deferred amount. Further information regarding the deferral of LPT is available on the Revenue website at: www.revenue.ie/en/property/local-property-tax/deferral-of-payment/index.aspx.

For the LPT valuation period 2026-2030, the income threshold for a single person to qualify for a full deferral is €25,000, and for a partial deferral is €40,000. For a couple, the income threshold to qualify for a full deferral is €40,000, and for a partial deferral is €55,000.

It is also possible to apply for a deferral on the grounds of hardship where a person suffers an unexpected and unavoidable significant loss or expense, as a result of which a person cannot pay their LPT liability without suffering financial hardship.

Any property owners experiencing difficulties can avail of a wide range of flexible payment options both in respect of their LPT liabilities and for any previous years where liabilities remain outstanding. The full range of payment options, which includes phased arrangements, are available to property owners on the Revenue website at: www.revenue.ie/en/property/local-property-tax/paying-your-lpt/index.aspx.

For these reasons, it is my view that a property tax system that is calculated on the basis of property value, with supports in place for those who need assistance, is appropriate and fair.

Question No. 138 answered with Question No. 137.
Question No. 139 answered with Question No. 137.
Question No. 140 answered with Question No. 137.
Question No. 141 answered with Question No. 137.

Tax Code

Ceisteanna (142)

Barry Ward

Ceist:

142. Deputy Barry Ward asked the Tánaiste and Minister for Finance if he will consider extending the provisions of the commuter ticket incentive so as not to disadvantage commuters who are just outside the band; and if he will make a statement on the matter. [66409/25]

Amharc ar fhreagra

Freagraí scríofa

Thank you for your question where I will assume you are referring to the TaxSaver scheme. The scheme is provided for by section 118(5A) of the Taxes Consolidation Act 1997 (TCA) and allows for an exemption from benefit-in-kind (BIK) in the case where an employer purchases a travel pass for one of their employees or directors.

Section 118B TCA also provides for that an employer and employee may enter into a salary sacrifice arrangement in exchange for a travel pass and as such BIK does not come into play.

Where a travel pass is purchased either under the TaxSaver scheme or through a salary sacrifice arrangement, certain conditions must be met including:

• the cost incurred must relate to a monthly or annual bus, railway or ferry travel pass;

• the travel pass must be issued by or on behalf of one or more approved transport providers; and

• the approved transport provider must be contracted or licensed to provide the transport services covered by the travel pass.

While the conditionality around the BIK exemption for the TaxSaver scheme falls under the remit of the Minister for Finance, I would ask the Deputy to note that the scope and conditions of the travel passes on offer are a matter for the individual transport providers. Furthermore, in respect of the day-to-day operations of public transport, including TaxSaver ticket offerings, it is the National Transport Authority that has responsibility for the regulation of fares charged to passengers in respect of public transport services provided under Public Service Obligation contracts.

In parallel, proposals in respect of all tax expenditure measures including the TaxSaver scheme, are assessed in accordance with my Department's Guidelines for Tax Expenditure Evaluation. It is important to note that Government policy is based on the principle that tax expenditures should be used in limited circumstances where a demonstrable market failure exists, and the measure is more efficient than a direct expenditure intervention. In its comprehensive review of the Irish tax system, the Commission on Taxation and Welfare (2022) supported this position.

In considering proposals to extend or expand any tax expenditures, the Government must be mindful of the public finances and the many demands on the Exchequer.

As with all tax expenditures and measures, the TaxSaver scheme is kept under review by my officials. I believe the scheme is operating as intended and I have no plans at present to amend the scheme.

Tax Code

Ceisteanna (143, 144)

Ken O'Flynn

Ceist:

143. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance if he will review the current VAT treatment applied to bus and coach operators; if he is aware that only tour operators are eligible to reclaim VAT on the purchase of new buses under the VAT 71 scheme, while school-bus and mixed-service operators who operate on significantly lower annual mileage and turnover are excluded; if he will assess the impact that this differential treatment is having on fleet renewal, vehicle supply, and costs faced by operators, particularly given the nationwide shortage of available buses and increased demand arising from new Local Link and public-transport services; if he will consider extending VAT recovery eligibility to all licensed bus operators to support the purchase of new vehicles and improve fleet quality; and if he will make a statement on the matter. [66431/25]

Amharc ar fhreagra

Ken O'Flynn

Ceist:

144. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance if he will examine the impact of VAT and customs duties on buses being imported from the UK by Irish operators; if he will consider measures to reduce the cost burden, given the current shortage of buses in the State; and if he will make a statement on the matter. [66432/25]

Amharc ar fhreagra

Freagraí scríofa

I propose to take Questions Nos. 143 and 144 together.

The VAT treatment of goods and services is subject to EU VAT law, with which Irish VAT law is obliged to comply. In general, the EU VAT Directive provides that all goods and services are liable to VAT at the standard rate, unless they fall within categories of goods and services specified in the Directive, in respect of which Member States may apply a lower rate, subject to strict rules including limits on the numbers of categories to which lower rates may be applied.

The Directive also requires that goods imported into a Member State from outside the EU are subject to VAT at the point of importation, and imported goods are liable to VAT as would apply if the goods were sold within the State.

Buses are not included in the categories of goods and services on which the EU VAT Directive allows a lower rate of VAT to be applied, and so they are liable to VAT at the standard rate – which in Ireland is currently 23% – when they are supplied in the State or when they are imported into the State from Great Britain or another third country. If buses are purchased by a business in the State from a business in another EU country or in Northern Ireland, then the Irish business must self-account for the VAT at the standard rate to Revenue.

The rate of VAT applying to buses in Ireland could only change if the standard rate of VAT were changed, however, all goods and services currently taxed at the standard rate would also be subject to such a change.

The EU VAT Directive allows for historic VAT treatment to be maintained by a Member State under certain conditions and, on this basis, Ireland has retained its application of VAT exemption to the transport of passengers and their accompanying baggage. This means that, under Ireland’s VAT rules, suppliers of passenger transport services, including school transport, do not register for VAT, do not charge VAT on the supply of their services and, consequently, have no VAT recovery entitlement on their input costs.

In accordance with the EU rules, Ireland may continue to apply this historic VAT exemption on the supply of domestic passenger transport but, for as long as the exemption remains, the conditions under which the exemption was granted cannot be changed. The introduction of a new entitlement to VAT recovery for the passenger transport sector could only be done if Ireland were to decide to end its historic exemption for the sector and bring passenger transport services into the VAT net; this would then require suppliers to register for VAT and require them to charge VAT on their passenger fares, including school transport. While the EU Directive permits a Member State to apply a zero rate of VAT to passenger transport services thereby enabling deductibility, this option is not currently open to Ireland because we already apply the Directive’s zero-rating to the maximum number of categories that is permitted.

Ireland has also maintained a relieving provision, the Value Added Tax (Refund of Tax) (Touring Coaches) Order of 2012, which provides for a refund of VAT on the cost of acquiring certain tour coaches by qualifying businesses. One of the key conditions of the Order, is that qualifying business is engaged in the business of carriage for reward of tourists by road under contract for group transport and that the vehicle is in that business. The Order does not extend to school transport.

The Deputy is asking about the possibility of extending the scope of the Order to all licensed bus operators, thereby allowing them to reclaim VAT on the purchase of new buses. Such a measure would not be compatible with the EU VAT Directive, particularly having regard to the conditions under which Ireland is permitted to maintain its historic VAT exemption for passenger transport.

Customs duty needs to be considered in relation to goods brought into State from outside the EU but not for the movement of goods within the EU. Customs duty rates are determined by the EU and as Customs is an EU competence, it is not possible for Ireland to apply a different rate as Customs duty rates are common across all Member States.

Buses imported into the State are generally subject to a customs duty of around 10% or 16% depending on the type of engine. However, imports of new and second-hand buses from the Great Britain (GB) into Ireland can claim a preferential tariff rate of 0% under the EU-UK Trade and Cooperation Agreement (TCA) where they can provide documentary proof that the bus is of UK origin. The documentation proving UK origin should be included with the Customs import declaration to allow the bus to be released to their owners in a timely manner. The proofs required to claim preferential origin are detailed in the TCA and are the same as the proofs required in other trade agreements that the EU has entered into, and generally come from the exporter, via the bus supplier or manufacturer.

There is also a Returned Goods Relief which may be available if the bus was originally exported from the EU to the UK, has not been altered and is being re-imported into the EU within three years of export. In accordance with the EU Customs Code, there are specific proofs required to qualify for the relief from Customs Duty and import VAT. In such circumstances, guidelines to the trade are updated regularly on the Revenue website and through Revenue’s direct communication to the trade via eCustoms Notifications.

Goods re-imported into the European Union guidelines: www.revenue.ie/en/customs/businesses/relief-duty-vat/reimported-into-eu/index.aspx.

eCustoms notifications: www.revenue.ie/en/customs/businesses/electronic-systems/ais/ecustoms-notifications/index.aspx.

Question No. 144 answered with Question No. 143.

Economic Policy

Ceisteanna (145)

Naoise Ó Cearúil

Ceist:

145. Deputy Naoise Ó Cearúil asked the Tánaiste and Minister for Finance to outline measures being taken to safeguard economic resilience given the Central Bank’s warnings on global market volatility; and if he will make a statement on the matter. [66469/25]

Amharc ar fhreagra

Freagraí scríofa

My Department continuously monitors global economic developments, including volatility in financial markets, for their potential impact on Ireland’s economy.Given this and other risks, Government has prioritised boosting the resilience of the Irish economy. That is why Budget 2026 focussed on investment. This will help maintain competitiveness and boost productivity which is the foundation for long-term improvements in living standards.Indeed, the Government has already been making significant strides in this regard. In July, Government set out in the National Development Plan its strategy to invest in the strategic objectives of energy, water, housing and transport.In September, together with the Taoiseach and Minister Burke, I launched the Government’s Action Plan on Competitiveness and Productivity - a whole-of-Government plan focusing on the domestic drivers of competitiveness.In August, I launched the Government’s Action Plan on Market Diversification with Minister Burke, which outlines the key areas on which we need to focus our efforts to ensure continued resilience and diversification.Maintaining the resilience of the public finances to any potential future shocks is a central pillar of Government’s fiscal strategy. Indeed, by the end of this year, we will have invested some €16 billion of ‘windfall’ tax receipts into the Future Ireland Fund and Infrastructure, Climate and Nature Fund. More generally, the best way to ensure that Government is in a position to respond to any future downturn is by running headline budgetary surpluses.

International Agreements

Ceisteanna (146)

Barry Heneghan

Ceist:

146. Deputy Barry Heneghan asked the Tánaiste and Minister for Finance the progress on Ireland’s international tax treaty negotiations currently under review; and if he will make a statement on the matter. [66500/25]

Amharc ar fhreagra

Freagraí scríofa

Ireland's long-standing tax treaty policy has been to expand, maintain, and enhance Ireland's tax treaty network to remove barriers and facilitate trade and investment opportunities between Ireland and partner jurisdictions.

In conducting a tax treaty there has to be sufficient trade, commercial, and economic reasons for doing so.

Tax 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. Furthermore, they provide for dispute resolution mechanisms and the exchange of taxpayer information to enhance tax transparency.

Ireland’s treaty base 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).

In June 2022, the Department of Finance published Ireland's tax treaty policy statement. This policy statement was developed following a public consultation with interested stakeholders and in coordination with other relevant Government Department.

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 priority, as per our Tax Treaty Policy statement, is to conclude treaties with G20 members, OECD and EU members, and accession states, as well as to update existing treaties.

Several of Ireland’s existing double tax agreements are over 40 years old and may not be fully in line with the provisions of more recent Irish treaties and current international norms. Some of these tax treaties may also be suitable for modernisation through renegotiation or the addition of protocols, taking due account of international tax developments.

Officials in the Department of Finance and the Revenue Commissioners are working to progress this policy statement.

Ireland has a number of ongoing and potential negotiations at this time. It is Ireland's policy to treat plans or 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, which respects the confidential nature of the negotiation process.

Departmental Programmes

Ceisteanna (147)

Barry Heneghan

Ceist:

147. Deputy Barry Heneghan asked the Tánaiste and Minister for Finance the steps are being taken to support financial literacy programmes nationally; and if he will make a statement on the matter. [66501/25]

Amharc ar fhreagra

Freagraí scríofa

Financial literacy is an essential life skill and an important part of financial consumer protection. It works alongside many other consumer protections in place to help consumers make the most of their money, make informed decisions and improve their financial resilience and well-being.

To support this skill, Ireland’s first National Financial Literacy Strategy was published in February this year.

The Strategy was built from extensive stakeholder engagement and the evidence base set out in a Mapping Report published in April 2024.

The focus of the five-year Strategy is to improve the level of financial literacy by working with Ireland’s financial literacy ecosystem – increasing cooperation, coordination and cohesion among stakeholders – and thereby supporting greater overall financial well-being and resilience.

My Department worked closely with a range of public and private sector organisations throughout the Strategy’s development. This included educators, the financial services industry, civil society and Government Departments and agencies. This engagement continues as we now implement the Strategy.

At the same time as the Strategy as published, my Department also launched:

• the 2025 Action Plan to support the implementation of the Strategy in 2025;

• a website to provide information about the National Financial Literacy Strategy and relevant research at www.financialliteracy.ie; and

• Guidelines for the Financial Services Industry delivering financial education in schools.

The 2025 Action Plan sets out actions stakeholders have agreed to take to fulfil the aims and objectives set out within the Strategy. Work is underway to develop a new action plan for 2026/2027, which I expect to publish early next year.

Departmental Data

Ceisteanna (148)

Michael Cahill

Ceist:

148. Deputy Michael Cahill asked the Tánaiste and Minister for Finance to examine issues with determining employment status (details supplied) and the implications on small builders; and if he will make a statement on the matter. [66530/25]

Amharc ar fhreagra

Freagraí scríofa

On 20th of October 2023, the Supreme Court (in a unanimous decision) delivered an important judgement on the key factors to be considered when classifying an individual’s employment status for income tax purposes. As a decision of the Irish Supreme Court, the judgement has application across all sectors, including the construction sector. Revenue, in carrying out its statutory function, is obliged to apply the judgement and has no discretion whatsoever on this matter.

The detailed judgment was delivered by Mr. Justice Brian Murray in The Revenue Commissioners v. Karshan (Midlands) Ltd. t/a Domino’s Pizza. The case concerned whether the delivery drivers were independent contractors under a “contract for service” and taxable under Schedule D of the Taxes Consolidation Act 1997, or were employees under a “contract of service”, and taxable under Schedule E of that Act (PAYE).

The judgement provides an extensive review of relevant caselaw, and succinctly summarises it through the provision of a five-step decision-making framework. The decision-making framework consists of five questions that are to be used to resolve the question of whether a contract is one of service (employee) or for service (self-employed). Under the self-assessment tax system, each business making payments to individuals is obliged to correctly determine whether individuals are employed or self-employed, based on the facts and circumstances of each relationship and payment through application of the five-step framework.

Revenue developed a detailed Tax and Duty Manual (TDM) to provide guidance in relation to the application of the judgment and to assist businesses who engage individuals to carry out work. The TDM (Part 05-01-30) was published on 21 May 2024 and is available at www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-05/05-01-30.pdf. It provides general guidance and commentary but cannot cover every eventuality and circumstance. The key message in the TDM is that in determining whether an individual is self-employed or an employee, the business (engaging the person) must apply the five-step framework by reference to the facts and circumstances of the individual case.

I am informed by Revenue that it has not imposed any approach, as it is the Supreme Court who has set down the conditions that need to be applied when classifying an individual’s employment status for income tax purposes. It has always been a matter for a business engaging the individual to determine whether that individual is an employee for tax purposes. Whether an individual is an employee depends on the application of the five-step framework to the facts and circumstances of the specific case.

Further, it is not necessary for an employee to work on a full-time basis for tax purposes. It was noted that an individual engaged on a part time or occasional basis may be an employee as there is no requirement for continuity of service in order to be an employee for tax purposes.

Following directly from the Supreme Court judgement in the Karshan case, Revenue announced in September 2025 that employers can correct payroll tax issues for 2024 and 2025 arising from bona-fide classification errors without having interest and penalty imposed. Employers who, acted in good faith relying on the case law and guidance available prior to the Supreme Court judgement, but who subsequently realise they misclassified employees as contractors, are encouraged to take this opportunity to regularise their tax affairs. 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.

Where an employer avails of this settlement opportunity, Revenue will accept liabilities for the settlement arrangement calculated as follows: Income Tax calculated at the rate of 20% on the gross amount paid to the employee during the relevant year, USC calculated based on a blended rate of 3.5% of the gross amount paid during the relevant year, PRSI (Employee and Employer contribution) must be calculated on an actual basis and records updated.

Where an employer fails to take this opportunity to review its workforce practices and make a relevant disclosure by 30 January 2026, and the liabilities from misclassification subsequently come to light, Revenue will form the view that the default has arisen from a complete failure to operate payroll 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 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.

Tax Collection

Ceisteanna (149, 150, 151)

Emer Currie

Ceist:

149. Deputy Emer Currie asked the Tánaiste and Minister for Finance the measures being put in place to monitor compliance rates, and to enforce full industry compliance with the requirements of the new e-liquid products tax, which came into effect on 1 November 2025, in particular noting that the new tax is subject to self-reporting. [66651/25]

Amharc ar fhreagra

Emer Currie

Ceist:

150. Deputy Emer Currie asked the Tánaiste and Minister for Finance the measures being put in place to monitor and enforce retailer compliance with the requirements of the new e-liquid products tax, noting recent media reports that certain alternative retailers selling vaping products have been subject to investigation by the Revenue Commissioners over concerns of tax evasions. [66652/25]

Amharc ar fhreagra

Emer Currie

Ceist:

151. Deputy Emer Currie asked the Tánaiste and Minister for Finance the date on which Government will publish the first data on e-liquid products tax compliance rates and enforcement actions. [66653/25]

Amharc ar fhreagra

Freagraí scríofa

I propose to take Questions Nos. 149, 150 and 151 together.

E-Liquid Products Tax (EPT) came into effect on 1 November 2025. The tax applies from that date to first supplies of e-liquid products in the State. Businesses who engage in the first supply of e-liquid products in the State are obliged to register and account for the tax. The first accounting period for the tax runs from 1 November until 31 December 2025. Returns for that period are due to be made by registered suppliers by 31 January 2026.

As with all new taxes, Revenue’s focus in relation to EPT in the early stages following its introduction is on providing support to taxpayers who are seeking to comply with their obligations, while actively working to identify and pursue those who are not. As the new tax becomes established, Revenue will undertake appropriate compliance work to ensure that businesses are properly registering, filing, and paying.

In designing the tax, a number of key administrative issues were considered including clear identification of what is to be taxed, the basis of assessment, the point of taxation and the liable person. Central to these considerations was ensuring that the tax was designed to encourage voluntary compliance by minimising the administrative burden on compliant taxpayers while enabling Revenue to identify and address non-compliance.

The tax follows Revenue’s standard model of self-assessment and applies on the first supply in the State of e-liquid products. This model places the tax charge at an early point in the supply chain, where there is typically a smaller number of operators, which supports effective administration and compliance. This means that importers and manufacturers of e-liquid products for sale are liable for the tax. While some shop owners may also be importers or wholesale suppliers, the majority of those required to register, file, and pay the tax, are manufacturers and importers.

Revenue fully utilises a comprehensive legislative framework that has been enacted by the Oireachtas to support its work against those who do not comply with their tax obligations, including the EPT. In accordance with section 65 of Finance Act 2024, it is an offence for any person to fail to comply with their EPT obligations. Such persons may, on summary conviction, be liable to a Class A fine. Furthermore, as EPT is an excise duty, relevant provisions of General Excise legislation set out in Finance Act 2001, as amended, are also available. These provisions provide for the raising of estimates and/or assessments to collect underdeclared EPT liabilities. Section 99C of Finance Act 2001 also provides for tax-geared penalties for carelessly or deliberately making incorrect returns or failing to make returns.

With its overall approach to compliance, Revenue focuses on identifying and quantifying risk, ensuring its compliance resources are focused on the non-compliant taxpayer, and minimising the administrative burden on the compliant taxpayer. To do this, Revenue uses a range of risk identification, assessment and evaluation programmes to monitor compliance of taxes generally. These processes are supported by real-time data analytics and the interrogation of both taxpayer and third-party information, including information on relevant licensing and regulatory frameworks.

The Deputy will be aware that the regulation of e-cigarette products, including their content, sale and promotion is the responsibility of my colleague the Minister for Health and is enforced principally through the network of Environmental Health Officers operating under the Health Service Executive.

In its Annual Report, Revenue publishes details of its own compliance activities across all taxes and duties. The Annual Report also includes information about the individual taxes including net tax receipts and it is expected that Revenue’s 2025 Report will include a report on the implementation of EPT. Revenue also publishes lists of tax defaulters on a quarterly basis. This list includes details of persons who have made a settlement with Revenue or for whom the Court has determined a penalty relating to a settlement or has imposed a fine or other penalty in respect of a tax or duty offence. Now that EPT has commenced, details of settlements and/or offences regarding EPT will also fall to be included in these publications as they arise.

As with all taxes and duties, Revenue welcomes and acts on intelligence received from businesses or from members of the public regarding actual or suspected tax non-compliance activity. This includes EPT. Details can be provided in confidence to Revenue by phone to 1800 295 295. Alternatively, information can also be provided in confidence via the Revenue website, or alternatively can be submitted directly to any Revenue office in writing.

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