Thursday, 7 May 2026

Written Answers Nos. 223-246

• Díospóireachtaí
• Aimsigh díospóireacht
  • Díospóireachtaí na Dála
  • Díospóireachtaí an tSeanaid
  • Díospóireachtaí Coiste
• Aimsigh vótáil
  • Vótálacha na Dála
  • Vótálacha an tSeanaid
  • Vótálacha Coiste
• Ceisteanna Parlaiminte
  • Ceisteanna scríofa
  • Ceisteanna ó bhéal
• Leideanna cuardaigh
• Nuair a bhíonn tionchar tromchúiseach ag aithrisí

Emergency Services

Ceisteanna (223)

Mattie McGrath

Ceist:

223. Deputy Mattie McGrath asked the Tánaiste and Minister for Finance the reason paramedics and emergency medical technicians (EMTs) do not receive the same level of flat rate expense allowances as other frontline healthcare professionals, such as nurses, despite carrying out comparable clinical duties and being subject to similar uniform and laundering requirements; and if he will consider extending eligibility for the uniform laundering allowance to paramedics and EMTs, given that nurses currently receive an allowance of approximately €353 per year. [33515/26]

Freagraí scríofa

Tánaiste and Minister for Finance

The flat rate expense (“FRE”) regime is operated by Revenue on an administrative basis, where both a specific commonality of expenditure exists across an employment category and the statutory requirement for the tax deduction as set out in section 114 of the Taxes Consolidation Act (“TCA”) 1997 is satisfied, namely, that the expenses are wholly, exclusively and necessarily incurred in the performance of the duties of the office or employment by the employee concerned and that such expenses are not reimbursed by his or her employer.

Revenue have advised that the FRE regime was established to apply a uniformity of approach to tax deductibility for expenses of large groups of employees and to facilitate ease of administration for both Revenue and employees. The expense should apply to all employees in that category and not be discretionary.

The FRE regime developed incrementally over the last 40 to 50 years and was established at a time when the numbers of employees/PAYE taxpayers filing an Income Tax Return was relatively low. This contrasts with the position today, whereby due to significant IT developments in Revenue systems in recent years, as well as the promotion of online channels, Revenue is now providing an easy to use, free, on-line Income Tax Return filing solution for taxpayers. For example, the number of PAYE taxpayers that filed an Income Tax Return for the 2023 tax year was over 1,100,000, when compared to the figure of under 300,000 in 2018.

Revenue have advised that the FRE is generally determined following engagement between Revenue and the relevant representative body. I am advised by Revenue that they have not received any formal application from a representative body on behalf of individuals working as paramedics for the National Ambulance Service or pre-hospital emergency care workers. I am further advised by Revenue that should the representative bodies for these groups wish to engage with Revenue further on the matter, Revenue will be happy to do so and will provide guidance on the supporting information required to enable the request to be considered.

Notwithstanding that an FRE is not available to either paramedics or pre-hospital emergency care workers, as for all employees, they retain their statutory right to claim a deduction under section 114 TCA 1997 in respect of an expense incurred wholly, exclusively and necessarily in the performance of the duties of their employment, to the extent to which the expenses are not reimbursed by the employer.

The quickest and easiest way to claim tax relief for qualifying employment expenses is to complete an online Income Tax Return. This return can be found in the PAYE Services tab in myAccount on the Revenue website.

Further guidance on the general rule of deduction of expenses in employment, including how to make a claim, is available on Revenue’s website at the following link: www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-05/05-02-20.pdf.

Court Sittings

Ceisteanna (224, 225, 226, 227)

Cian O'Callaghan

Ceist:

224. Deputy Cian O'Callaghan asked the Tánaiste and Minister for Finance when he was first made aware of a High Court case (details supplied); and if he will make a statement on the matter. [33545/26]

Cian O'Callaghan

Ceist:

225. Deputy Cian O'Callaghan asked the Tánaiste and Minister for Finance if he will initiate a review of the relevant legislation and processes in view of a judgement (details supplied); and if he will make a statement on the matter. [33546/26]

Cian O'Callaghan

Ceist:

226. Deputy Cian O'Callaghan asked the Tánaiste and Minister for Finance if an independent review will be undertaken of a case (details supplied); and if he will make a statement on the matter. [33547/26]

Cian O'Callaghan

Ceist:

227. Deputy Cian O'Callaghan asked the Tánaiste and Minister for Finance given the Central Bank Act 1942 states that applications to confirm a prohibition order should, insofar as practicable, be heard and determined within three months yet the President of the High Court has indicated that this timeframe is not achievable in practice; the action his Department is taking to ensure this provision becomes achievable in practice; and if he will make a statement on the matter. [33548/26]

Freagraí scríofa

Tánaiste and Minister for Finance

I propose to take Questions Nos. 224, 225, 226 and 227 together.

I am aware of the High Court judgment in this case and while the High Court notified the parties of its decision on a confidential basis in May 2025 there was no basis or requirement to share the judgment with any other parties.

I have been informed by the Central Bank that it takes the High Court judgment seriously and is in the process of thoroughly mapping the judgment against its current procedures to identify what changes are required and will make all the necessary changes to incorporate the judgment into its processes and procedures.

I would note that a number of changes have been already made to the Central Bank’s investigations pillar under the Fitness & Probity (F&P) regime since the time of the investigation and decision to which the judgment relates. These changes have been advanced and the recent written judgment has provided additional clarity and guidance that will be built into internal and external processes and procedures to ensure fairness and robustness of Central Bank investigations in the future.

Furthermore since the decision was made by the Central Bank in this investigation, it has also introduced enhanced scrutiny and oversight on F&P cases in the pipeline to ensure that fair procedures are provided to all persons the subject of an investigation that are consistent with the findings of the judgment.

The Central Bank has also provided the following information highlighting the following material changes which have taken place in the years since this case:

• In 2023, the Central Bank (Individual Accountability Framework) IAF Act 2023 came into effect and introduced a number of changes to the investigations pillar of the F&P Regime. These changes enhanced the procedures in processes and the 2010 Act enshrined the independence of the prohibition decision makers. The Central Bank revised and published updated guidance on ‘Fitness and Probity Investigations, Suspensions and Prohibitions’ and Regulations governing the conduct of investigations in April 2023.

• In July 2024, the Central Bank published the independent review of the F&P Regime. The review was undertaken by Mr Andrea Enria (Enria Report). While the review focused on the gatekeeper pillar of the regime the specific recommendations around fairness, efficiency and transparency of process have been adopted by the Central Bank into the broader operation of the F&P regime to include the F&P investigation pillar. Examples include the fact that at the earliest point in the investigation process, the subject is provided with an overview of the end-to-end process and is kept up to date on the progress of the investigation through regular engagement.

• On 28 January 2026 the Central Bank launched a public consultation on prohibition notices which concluded on 25 March 2026 with final guidance expected in the coming months. This guidance will take into account the recommendations arising from the Enria Report in the preparation of the draft guidance on prohibition notices. The Central Bank have also informed me that it will also take into account the judgment referred to by the Deputy in finalising this guidance.

• Prior to the High Court judgment, the Central Bank was undertaking work on enhancing its process and procedures for the conduct of oral hearings for all ongoing and future cases.

In response to your question on the 3 months confirmation target, the Central Bank provided the following information:

• The majority of prohibition notices imposed by the Bank were agreed with the relevant person and so did not require Court confirmation.

• The IAF Act 2023 amended the Central Bank Act 2010 to provide that a prohibition notice does not take effect until confirmed by the Court unless otherwise agreed to take effect without confirmation in accordance with section 46.

As such, persons are no longer prohibited while the Court confirmation process is ongoing. Thus, the legislation introduced in 2024 has provided an effective remedy.

Taking these issues and changes into account, I do not see a need to undertake a review of the relevant Central Bank legislation or the operational processes within the Central Bank at this time.

However, I do expect the Central Bank to continue to engage with all stakeholders in improving its processes and procedures in line with an ongoing commitment to reform.

Question No. 225 answered with Question No. 224.

Question No. 226 answered with Question No. 224.

Question No. 227 answered with Question No. 224.

Departmental Inquiries

Ceisteanna (228, 229, 230)

Cian O'Callaghan

Ceist:

228. Deputy Cian O'Callaghan asked the Tánaiste and Minister for Finance if compensation mechanisms are in place for the losses incurred for a person (details supplied) as a result of being prevented from working, given that the process has extended for nearly seven years; and if he will make a statement on the matter. [33549/26]

Cian O'Callaghan

Ceist:

229. Deputy Cian O'Callaghan asked the Tánaiste and Minister for Finance given that costs were awarded against an organisation in a case (details supplied), the total cost to the Exchequer to date arising from this case; and if he will make a statement on the matter. [33550/26]

Cian O'Callaghan

Ceist:

230. Deputy Cian O'Callaghan asked the Tánaiste and Minister for Finance if he will consider establishing a compensation or protection fund to support individuals who suffer loss arising from wrongful prohibitions or from investigations that are ultimately discontinued such as took place in a case (details supplied); and if he will make a statement on the matter. [33551/26]

Freagraí scríofa

Tánaiste and Minister for Finance

I propose to take Questions Nos. 228, 229 and 230 together.

I am aware of the High Court judgment in this case and while the High Court notified the parties of its decision on a confidential basis in May 2025 there was no basis or requirement to share the judgment with any other parties at that time.

There are various avenues open to individuals and firms to challenge decisions of the Central Bank, including depending on the decision, appeals to the Irish Financial Services Appeals Tribunal (IFSAT) or a judicial review of the decision.

In terms of timing, it should be noted that the Central Bank (Individual Accountability Framework) (IAF), 2023 amended the Central Bank Act 2010 to provide that a prohibition notice does not now take effect until confirmed by the High Court unless otherwise agreed in accordance with section 46, where an individual is in agreement with the prohibition.

Public bodies, including the Central Bank, when carrying out statutory duties do so within the limits of the legislative provisions that underpin their actions.

Section 45, Central Bank Act 2010 does not provide for compensation and I do not see a basis on which the compensation mechanism proposed by the Deputy could operate efficiently or effectively. There would need to be a strong policy rationale to consider such a change in the law.

Indeed, such an approach could likely have implications for other State entities, outside the area of financial services, that have similar powers of investigation and application of penalties as the Central Bank.

On the matter of costs, the Central Bank has informed me that it is too early to determine the full costs of this case. The timeline for initial quantification of costs is 28 days from the perfection of the Order by the High Court and this has not yet happened.

In terms of costs, the Central Bank of Ireland is self-funding though its own income and the industry levy and is a body not in receipt of funds from the Exchequer for its daily operations. Accordingly, any such costs do not arise as a direct charge on the Exchequer.

Question No. 229 answered with Question No. 228.

Question No. 230 answered with Question No. 228.

Services Sector

Ceisteanna (231)

Michael Cahill

Ceist:

231. Deputy Michael Cahill asked the Tánaiste and Minister for Finance to consider correspondence (details supplied) and allow for a reduction in Vat, to 9% for the beauty industry in line with hairdressers and barbers; and if he will make a statement on the matter. [33575/26]

Freagraí scríofa

Tánaiste and Minister for Finance

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. In general, the EU VAT Directive provides that all goods and services are liable to VAT at the standard rate, unless they are exempt from VAT or fall within the categories of goods and services listed in Annex III of the EU VAT Directive, to which Member States are permitted to apply lower VAT rates subject to certain rules.

Beauticians are not included in the categories of goods and services on which the EU Directive allows a lower rate of VAT, and therefore they would fall to be taxed by Member States at their standard rate of VAT – which in Ireland is currently 23%. However, the Directive allows that a Member State may retain certain long-standing VAT arrangements that they had in place, subject to strict conditions including that the terms of the historic arrangement cannot be extended.

On this basis, Ireland is permitted to retain its long-standing application of its reduced VAT rate – which is currently 13.5% – to services related to the care of the human body, which includes beautician services. In accordance with the Directive this arrangement is treated as a ‘parked’ rate, which means that it cannot be reduced below 12%. If Ireland were to cease the application of the parked rate to these supplies, then under the terms of the Directive these services would have to be subject to the standard rate of VAT.

As hairdressing services are specifically included in Annex III and are not a ‘parked’ item, it is possible to apply the 9% rate to them. Therefore, in accordance with Finance Act 2025 the 9% rate will apply to hairdressing services from 1 July 2026. This measure includes hairdressing services provided by beauticians but does not extend to other beauty services.

Revenue Commissioners

Ceisteanna (232, 233, 234, 235)

Ken O'Flynn

Ceist:

232. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance whether any statutory provision within the Vehicle Registration Tax regime provides for exemptions, waivers or reduced liability in respect of vehicles imported by individuals who are subject to a protection order or similar court order; and if he will specify the legislative basis for same. [33582/26]

Ken O'Flynn

Ceist:

233. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance whether the Revenue Commissioners have any discretionary authority to waive or reduce Vehicle Registration Tax in exceptional or humanitarian circumstances, including cases involving individuals subject to protection orders; and if so, to outline the criteria governing such discretion. [33583/26]

Ken O'Flynn

Ceist:

234. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance whether his Department has conducted any assessment of the impact of Vehicle Registration Tax and associated motor taxation requirements on individuals in vulnerable circumstances, including those subject to protection orders; and whether any policy review is planned. [33584/26]

Ken O'Flynn

Ceist:

235. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance whether responsibility for considering financial or administrative reliefs for individuals subject to protection orders in respect of vehicle importation is assigned to his Department, the Revenue Commissioners, or another body; and if he will clarify the policy framework governing such cases. [33585/26]

Freagraí scríofa

Minister for Finance (Deputy Simon Harris)

I propose to take Question Nos 232, 233, 234, and 235 together.

I understand that the Deputy’s question relates specifically to individuals who have sought protection from the courts in the context of domestic violence or similar circumstances, and whether there are any specific legislative provisions under the vehicle registration regulatory framework which deal with circumstances where such individuals are importing and registering a vehicle in the State. 

The Finance Act 1992, as amended, sets out the rules governing vehicle registration and Vehicle Registration Tax (VRT). In general, the legislation obliges an individual who brings a vehicle into the State to register it within 30 days, and VRT is charged at the point of registration. 

Permanent reliefs from VRT are set out in section 134 of the Act and in the Vehicle Registration Tax (Permanent Reliefs) Regulations, 1993 (S.I. No. 59/1993). These reliefs may be available to persons transferring their residence or business permanently to Ireland, to persons covered by the Disabled Drivers and Disabled Passengers Tax Relief Scheme, to transfers of vehicles which were the personal property of persons recently deceased, to diplomats and to certain EU officials based in the State.

Temporary reliefs from the requirement to register a vehicle are set out in Section 135 of the Act and in the Temporary Exemption from Registration of Vehicles Regulations, 1993, (S.I. No. 60 of 1993). These provide for certain limited circumstances in which a vehicle that is temporarily brought into the State may be exempted from the requirement to be registered. Such temporary exemption may be available, for example, in situations where a vehicle is brought into the State by a person established outside the State for private or business use or, where a vehicle is brought into the State solely for the purpose of a competition, exhibition, show, demonstration, or similar purpose and is not intended to be sold or offered for sale in the State. Such exemptions do not extend to vehicles separately imported into the State. 

Any person applying for a relief from the requirement to pay vehicle registration tax must do so under one of these provisions. There are no statutory or discretionary reliefs from VRT or vehicle registration requirements specifically for individuals who are protected by a protection order or similar court order.

Vehicle tax policy is reviewed as part of the annual Budget and Finance Bill process, including consideration of policy options and proposals via the Tax Strategy Group.

Departmental Funding

Ceisteanna (236, 237, 253, 262)

Paula Butterly

Ceist:

236. Deputy Paula Butterly asked the Tánaiste and Minister for Finance if he will provide a list of all capital projects and programmes funded or overseen under the remit of his Department, and bodies under its aegis, which have been completed on time and within budget in Louth in each of the past five years, in tabular form; and if he will make a statement on the matter. [33620/26]

Emer Currie

Ceist:

237. Deputy Emer Currie asked the Tánaiste and Minister for Finance if he will provide a list of all capital projects and programmes funded or overseen under the remit of his Department, and bodies under its aegis, which have been completed on time and within budget in Dublin West in each of the past five years, in tabular form; and if he will make a statement on the matter. [33671/26]

Barry Ward

Ceist:

253. Deputy Barry Ward asked the Tánaiste and Minister for Finance if he will provide a list of all capital projects and programmes funded or overseen under the remit of his Department and bodies under its aegis, which have been completed on time and within budget in Dublin in each of the past five years, in tabular form; and if he will make a statement on the matter. [33817/26]

Brian Brennan

Ceist:

262. Deputy Brian Brennan asked the Tánaiste and Minister for Finance if he will provide a list of all capital projects and programmes funded or overseen under the remit of his Department, and bodies under its aegis, which have been completed on time and within budget in the Wicklow Wexford Constituency in each of the past five years, in tabular form; and if he will make a statement on the matter. [33930/26]

Freagraí scríofa

Tánaiste and Minister for Finance

I propose to take Questions Nos. 236, 237, 253 and 262 together.

I wish to advise the Deputies that there have been no capital projects or programmes funded or overseen under the remit of my Department in Dublin West, Louth, Dublin, Wicklow or Wexford in the past five years.

The Central Bank is the only body that had capital projects and programmes completed (on time and within budget) in the past five years. All were completed in Dublin and are listed in the table below.

The Central Bank (CBI)

	Dublin
2025	CITRUS Technology Refresh 2023-2025
2024	New eDiscovery Software Solution Market Surveillance System Acquisition Website Cloud Migration and Development Treasury Management System Project Server Upgrade & Data Migration Payment Statistics Regulation Update Future @ Work
2023	N/A
2022	HSM Replacement Data Centre
2021	Analytics Platform Technology Refresh Technology Resilience Remediation

Note: The Central Bank has not included details for 2026 as these have not yet been finalised.

Question No. 237 answered with Question No. 236.

State Bodies

Ceisteanna (238)

Aidan Farrelly

Ceist:

238. Deputy Aidan Farrelly asked the Tánaiste and Minister for Finance if his Department or any bodies and agencies under his aegis use software and or products from a company (details supplied); and the duration and cost of the contract; and the services they avail of from the company. [33720/26]

Freagraí scríofa

Tánaiste and Minister for Finance

I am advised that neither my Department, nor any of the Bodies under the Aegis of my Department, use software and or products from the supplier "Passworks".

Trade Data

Ceisteanna (239, 240, 241, 248)

Ken O'Flynn

Ceist:

239. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance the estimated annual Exchequer yield attributable to the deemed disposal regime as it applies to Exchange Traded Funds and other gross roll-up investment products held by individual retail investors; and to provide a breakdown of this yield for each of the past five years. [33767/26]

Ken O'Flynn

Ceist:

240. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance whether the Department has undertaken any forward projections or dependency analysis in respect of Exchequer revenues arising from the deemed disposal regime; and if so, to provide details of such projections. [33768/26]

Ken O'Flynn

Ceist:

241. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance what empirical analysis, behavioural modelling, or impact assessments have been undertaken since the introduction of deemed disposal in 2006 to evaluate its effectiveness in preventing tax deferral or avoidance by retail investors; and if none have been undertaken, to confirm same. [33769/26]

Ken O'Flynn

Ceist:

248. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance whether the Department has conducted any costings, scenario modelling, or fiscal impact assessments in relation to the abolition or reform of the deemed disposal regime as it applies to retail investors; and if so, to provide details of same. [33776/26]

Freagraí scríofa

Tánaiste and Minister for Finance

I propose to take Questions Nos. 239, 240, 241 and 248 together.

The Deputy has asked about the Exchequer impact of deemed disposal. The tax revenue arising from the taxation of investment funds and life assurance policies, including deemed disposal rules, was examined in the context of Budget 2026. The information available to Revenue does not allow them to isolate the tax returned due to deemed disposal rules from other chargeable events which give rise to a tax liability. Chargeable events include:

- the making of relevant payments,

- the redemption of the investment,

- the transfer by an investor of their investment, and

- the ending of an eight-year period following the acquisition of the investment and then every eight years thereafter. This is commonly referred to as a deemed disposal.

Therefore, it is not possible to identify directly the tax revenue arising from the application of deemed disposal rules. This is because investment funds are not obliged to report the category of chargeable event that the exit tax relates to at the time of making payment to Revenue. Similarly, as respects investments in certain Irish domiciled funds and offshore funds in respect of which investors are required to self-assess tax due, taxpayers are not required to separately report data for each category of chargeable event when filing their tax return.

Therefore, while it is possible to identify the amounts of tax paid by funds in respect of unit holders, being Investment Undertaking Tax (IUT), and income tax accounted for by individuals in respect of their investments in Irish domiciled funds and offshore funds, it is not possible to provide a breakdown of the tax which relates to the eight-year deemed disposal nor is it possible to provide data on the number of individuals who are impacted by the deemed disposal rule.

On the basis of the information available to Revenue, and based on tax paid over the last eight years, if it was assumed that all tax paid by funds in respect of unit holders, tax paid by life companies in respect of policy holders, and income tax accounted for by individuals in respect of their investments in Irish domiciled funds, offshore funds and life products were as a result of deemed disposal, removing deemed disposal could give rise to a potential cost of €284 million. For Budget 2026, an estimate was prepared for the Exchequer impact in a year where deemed disposal did not apply, assuming that deemed disposal was closer to 50% of the total tax paid. This assumption results in an estimated full year cost to the Exchequer of €142 million for the removal of deemed disposal for investment funds and life assurance products.

However, it is important to note that the actual cost could vary where the proportion of tax which arises from deemed disposal rules is higher or lower, as well as where the gains in a particular year are larger or smaller than the eight-year average used for this estimate.

No specific empirical analysis of the impact of deemed disposal on tax deferral has been undertaken. It is the case that the operation of the deemed disposal rules, by including a charge to tax every eight years, ensures that tax is not deferred indefinitely.

My Department forecasts a number of income tax sub-heads, including PAYE, USC and smaller components such as Life Assurance Exit Tax (LAET). In addition, other taxes such as Investment Undertaking Tax (IUT) are included within general income tax forecasts. The most recent set of projections for income tax, published in the Annual Progress Report, take into account the latest macroeconomic projections and policy factors, such as the decrease in the LAET and IUT rate introduced in Budget 2026.

The table below provides the estimated amount of overall tax arising from 2016 to 2024 in respect of investments in investment funds, including IUT and income tax on Irish domiciled funds and certain offshore investment funds, which includes amounts in respect of ETFs. It also included tax arising from life assurance products, including LAET. Data for 2025 is not yet available. As noted above it is not possible to identify the tax arising from the application of deemed disposal rules.

Year	Tax on Offshore Funds* €m	Tax on Foreign Life Policies* €m	IUT €m	LAET** €m	Total €m
2024	*	*	73.5	169	242.5
2023	29.4	0.6	90.8	231	351.8
2022	33.8	1.0	82.1	233	349.9
2021	62.0	1.0	57.3	129	249.3
2020	33.0	0.8	39.1	124	196.9
2019	28.6	0.4	28.0	128	185
2018	21.0	0.6	39.7	165	226.3
2017	25.6	2.0	39.6	184	251.2
2016	22.4	0.3	37	228	287.7

*Total gross tax liability on income / gains from offshore funds and foreign life policies per Form 11 return. Form 11 data for 2024 is not yet available.

** IUT and LAET represent the amount of tax paid to Revenue. It is not possible to identify whether the figures for IUT and LAET represent amounts taxed at 25% in respect of corporate investors or 41% in respect of individual investors.

Question No. 240 answered with Question No. 239.

Question No. 241 answered with Question No. 239.

Revenue Commissioners

Ceisteanna (242, 246, 247, 249)

Ken O'Flynn

Ceist:

242. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance whether any analysis has been conducted by his Department, the Revenue Commissioners, or any external body on whether the deemed disposal regime influences retail investor behaviour, including investment decisions relating to Exchange Traded Funds versus direct equity holdings or non-EU domiciled products; and if so, to provide details. [33770/26]

Ken O'Flynn

Ceist:

246. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance whether any analysis has been conducted on the distributional impact of the deemed disposal regime across income cohorts, including its effect on small and medium retail investors; and if so, to provide details. [33774/26]

Ken O'Flynn

Ceist:

247. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance whether the Department has assessed the impact of the deemed disposal regime on retail participation rates in diversified investment funds; and if so, to provide any data or analysis available. [33775/26]

Ken O'Flynn

Ceist:

249. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance whether the deemed disposal regime has been assessed in the context of recent European Commission recommendations on savings and investment accounts; and if so, to outline any alignment or divergence identified. [33777/26]

Freagraí scríofa

Tánaiste and Minister for Finance

I propose to take Questions Nos. 242, 246, 247 and 249 together.

In terms of analysis of the impact of the current taxation system and the deemed disposal rule in particular, on retail investment, I would note that in December 2025, the Central Bank published a report Retail Investor Participation in Ireland Consumer Research and Analysis, which can be found on their website. This report notes that “the decision to invest is driven by a complex interplay of factors, including economic conditions, personal financial circumstances and psychological biases. It is notable that historically, participating in capital markets has not been viewed as an option for most Irish consumers. This combined with periods of significant market volatility may have played a role in the development of a financial culture with relatively low levels of trust and risk appetite, which favours cash and deposits over investments”. The analysis suggests that the key obstacles to investment identified by non-investors are a lack of financial resources, psychological or emotional barriers and knowledge and understanding gaps. Taxation was not identified as significant consideration for non-investors. However, it is the case that for existing retail investors, taxation was identified as a factor in their investment decision. According to the Central Bank’s research, 35% of investors reported that tax is a factor when considering an investment product. A key consideration is value, determined by the return on investment, after fees and tax have been deducted. This Central Bank research and analysis is being considered in the context of the work underway on the roadmap for the taxation of retail investment.

The roadmap will take the Funds Review and the European Commission's Savings and Investment Account recommendation into consideration. A key aspect of the roadmap is the development of a new Irish investment account that aims to reduce the complexities related to retail investment taxation and allows Irish people to grow their savings more efficiently.

Tax Data

Ceisteanna (243, 244, 245, 250)

Ken O'Flynn

Ceist:

243. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance to identify any EU or OECD jurisdiction that applies a taxation mechanism equivalent to Ireland’s deemed disposal regime, including the taxation of unrealised gains within regulated retail investment funds; and if no such jurisdiction exists, to set out the policy rationale for maintaining such a regime in Ireland. [33771/26]

Ken O'Flynn

Ceist:

244. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance to outline the effective tax rates applicable to Exchange Traded Fund investments under the deemed disposal regime compared with the standard capital gains tax rate applied to direct equity investments; and to confirm whether any internal assessment has been conducted on the relative impact of these differing rates. [33772/26]

Ken O'Flynn

Ceist:

245. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance the policy rationale for the prohibition on offsetting losses within the deemed disposal regime, including whether any review has been undertaken of this restriction in comparison with standard capital gains tax treatment. [33773/26]

Ken O'Flynn

Ceist:

250. Deputy Ken O'Flynn asked the Tánaiste and Minister for Finance to provide a detailed timeline for the publication of the roadmap on the taxation of retail investment, including whether the roadmap will include specific proposals relating to deemed disposal; and if so, to provide details. [33778/26]

Freagraí scríofa

Tánaiste and Minister for Finance

I propose to take Questions Nos. 243, 244, 245 and 250 together.

Individual jurisdictions design their tax systems to meet their specific requirements, and deemed disposal was introduced in Ireland in order to prevent indefinite roll-up, as an anti-avoidance measure, in response to actual investor behaviour at the time. I am aware that earlier this year the Dutch House of Representatives passed legislation to introduce a flat rate tax of 36% on actual returns from savings and investments, as well as unrealized gains, effective from 1 January 2028. I would also note that a number of OECD jurisdictions have a special framework to encourage investment, with a range of different beneficial tax treatments for investments. My Department is carefully considering the range of approaches across other jurisdictions, as well as the European Commission blueprint for a Savings and Investment Account, as part of the work underway to develop a new approach to the taxation of retail investment.

Turning to the differences between the taxation of investment funds and direct investments, where, for example, an Irish resident individual invests directly in a company by acquiring shares rather than investing in an investment fund, any income payments received (dividends) are subject to income tax at the individual’s marginal rate and gains from the disposal of shares are subject to Capital Gains Tax (CGT) at a rate of 33%. In contrast, where an individual has invested in a domestic investment fund the gross roll-up regime applies, such that there is no annual tax on income or gains arising to a fund, but the fund has responsibility to deduct on exit, known as investment undertaking tax (IUT) in respect of payments made to certain unit holders in that fund, and the deemed disposal rule applies. However, for certain investment funds where the units are held on a recognised clearing system, such as the case with ETFs, the fund is not required to deduct exit tax, and the investor must self-assess the tax due. Whether the investment fund accounts for exit tax or that tax is collected through self-assessment, the amount of the gain is subject to tax at a rate of 38% for individuals, or 25% if the investor is a company (a higher rate can apply where the investment fund is a personal portfolio investment undertaking).

The rate of tax applicable to investment funds may be distinguished from the rates applicable to income and gains from other investment products due to availability of the ‘gross roll-up’ regime, where the income and gains can roll-up tax free within the fund. Investment funds make multiple disposals of assets over the lifetime of the fund which are not individually taxed. The value that passes to an investor in an investment fund, in respect of which tax at a rate of 38% generally applies, will reflect a combination of both the income and gains from the underlying investments in the fund.

Loss relief is not available in respect of losses arising on disposals of units in investment funds which are subject to the gross-roll up regime. IUT is not a tax on investors, but on the fund itself and the fund is required to compute the tax, deduct the tax and return it to Revenue. Irish tax legislation specifically provides that IUT is a liability of the fund. Therefore, as the investor is not taxed on the gain arising on a chargeable event, the investor is accordingly not entitled to relief in respect of losses arising.

I am committed to taking the necessary action to support retail investment in Ireland. Budget 2026 introduced a reduction in the taxation rate that applies to Irish and equivalent offshore funds and Irish and certain foreign life assurance products, from 41% to 38%. This change also applies to investments in Exchange-Traded Funds (ETFs) that are taxed under these regimes.

Budget 2026 also included a commitment to publishing a roadmap for the taxation of retail investment, setting out an approach to simplify and adapt the tax framework to further support retail investment while retaining necessary and important anti-avoidance protections in a proportionate manner. The roadmap will be published in the coming months. The roadmap will take the Funds Review and the European Commission's Savings and Investment Account recommendation into consideration. A key aspect of the roadmap is the development of a new Irish investment account that aims to reduce the complexities related to retail investment taxation and allow Irish people to grow their savings more efficiently.

Question No. 244 answered with Question No. 243.

Question No. 245 answered with Question No. 243.

Question No. 246 answered with Question No. 242.

• Written Answers Nos. 207-222
• Written Answers Nos. 247-276