Dáil Éireann Debate, Wednesday - 25 March 2026
52. Deputy Alan Kelly asked the Tánaiste and Minister for Finance the total revenue generated by the domicile levy for each year since its introduction to date; the number of individuals who paid the levy in each of those years; the total amount of Irish income tax paid by non-resident Irish-domiciled individuals for each year from 2008 to date in 2026, in tabular form; and if he will make a statement on the matter. [23018/26]
Amharc ar fhreagra53. Deputy Alan Kelly asked the Tánaiste and Minister for Finance the number of individuals who were liable for and paid the domicile levy in the years 2020 to 2025 inclusive who also held a designated directorship or a position in senior office as defined under the Ethics in Public Office Acts during the same period or any other appointment to the board of a body under the aegis of a Government Department or who were nominated or supported by the Government for a renumerated or voluntary position within or outside of the State, in tabular form; and if he will make a statement on the matter. [23021/26]
Amharc ar fhreagra54. Deputy Alan Kelly asked the Tánaiste and Minister for Finance the number of late or non-payments of the domicile levy by individuals liable for it in each of the years 2020 to 2025, in tabular form. [23022/26]
Amharc ar fhreagra55. Deputy Alan Kelly asked the Tánaiste and Minister for Finance to provide a list of countries outside of Ireland where those who were liable for the domicile levy listed as their addresses in 2025. [23023/26]
Amharc ar fhreagraI propose to take Questions Nos. 52, 53, 54 and 55 together.
The Deputy will be aware that the Domicile Levy was introduced in the Finance Act 2010. The purpose of the levy is to ensure that Irish domiciled individuals with substantial income and assets located in the State make a contribution to the exchequer. The levy applies to a “relevant individual”, which means an individual:
• who is domiciled in Ireland in the tax year,
• whose world-wide income in the tax year exceeds €1m,
• whose liability to Irish income tax in the tax year is less than €200,000, and
• who owns Irish property on 31 December in the tax year where the market value of that property is greater in value than €5m.
The amount of the levy, where it applies, is €200,000 per annum. Irish income tax paid by an individual for a tax year is allowed as a credit in calculating the amount of the domicile levy which is chargeable for that year and, in recognition of this income tax payment, the amount of the levy to be paid may be lower than €200,000. The levy is payable on a self-assessment basis on or before 31 October in the year following the valuation date, which is 31 December. Domicile Levy returns for 2025 are not due to be filed until 31 October 2026 so the latest figures available are for 2024.
Table 1 sets out the total number of individuals who paid the Domicile Levy for the years 2010 to 2024 and the actual payments made. Table 1 also sets out income tax paid on all income assessed (not just Irish income) in relation to Form 11 filers from 2018 to 2023, which is the latest year data is available for. Form 11 is filed by "chargeable persons"—typically self-employed individuals, sole traders, partners, and proprietary directors—to declare annual income, gains, and self-assessment tax to Revenue. Prior years cannot be provided due to the way in which the tax return was structured, as it did not include specific separate questions on domicile and residency status.
Table 1: Domicile Levy Returns and/or Payments for the years 2010 to 2024
|
Tax Year |
Number of Returns and / or payments |
DL Paid €m (rounded) |
Income Tax Liability* (including USC) €m
|
|
2010 |
37 |
€4.8 |
- |
|
2011 |
33 |
€4.7 |
- |
|
2012 |
26 |
€3.5 |
- |
|
2013 |
19 |
€2.9 |
- |
|
2014 |
13 |
€2.0 |
- |
|
2015 |
21 |
€3.0 |
- |
|
2016 |
18 |
€2.2 |
- |
|
2017 |
25 |
€3.1 |
- |
|
2018 |
12 |
€2.2 |
€57 |
|
2019 |
20 |
€2.9 |
€68 |
|
2020 |
19 |
€2.9 |
€70 |
|
2021 |
19 |
€1.9 |
€91 |
|
2022 |
15 |
€2.4 |
€83 |
|
2023 |
18 |
€2.9 |
€98 |
|
2024 |
13 |
€2.1 |
- |
|
Total |
308 |
€43.5m |
€467m |
These figures are based on taxpayer units, a taxpayer unit refers to an individual except in the case of couples who are married or are in a civil partnership and have opted for joint assessment, in which case those two individuals are counted as one taxpayer unit and are assessed to tax together. In the case of jointly assessed couples the individual who is non-resident and the person who is non-domiciled can be either partner in the unit and it is not always the same person in the unit who fulfils both criteria specified.
Revenue do not collect data regarding directorships or board membership (public, voluntary or otherwise) for individuals who are liable for the Domicile Levy.
To be liable for the Domicile Levy taxpayers must meet the qualifying criteria as set out in paragraph 1. Therefore, due to changing circumstances, taxpayers may not be liable for consecutive years. Table 2 sets out the number of individuals liable for the Domicile Levy who made late payments from 2020 to 2024.
Table 2: Domicile Levy late payments for the years 2020 to 2024
|
Domicile Levy Year |
No of individuals with late payments |
|
2020 |
<10 |
|
2021 |
<10 |
|
2022 |
<10 |
|
2023 |
<10 |
|
2024 |
<10 |
I am advised by Revenue that, due to its obligation to maintain taxpayer confidentiality, as provided for in Section 851A of the Taxes Consolidation Act 1997, and to uphold its Statistical Disclosure Control Protocol, specific data in relation to late payments cannot be provided. Revenue only provide data in relation to groupings of 10 or more taxpayers. More information on Revenue’s Statistical Disclosure Controls can be found on the Revenue website.
As per Table 1, there were 13 payments in 2024 for the Domicile Levy. I am further advised by Revenue that having reviewed the addresses of the 13 taxpayers who were liable for the Domicile Levy in 2024, there is no country where 10 or more taxpayers reported as their address and therefore the list of countries outside Ireland requested cannot be provided.
