Dáil Éireann Debate, Thursday - 21 May 2026
213. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance the estimate revenue that would be raised by applying an entity level tax on the REITs and IREF at a rate of 1% of the total value of the assets held in these structures. [38562/26]
Amharc ar fhreagra214. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance the revenue that would be raised by removing all exemptions to the withholding tax for IREFs. [38563/26]
Amharc ar fhreagraI propose to take Questions Nos. 213 and 214 together.
An Irish Real Estate Fund (“IREF”) is an Irish regulated investment fund, or sub fund where at least 25% of the value of its assets is derived from Irish property such as land and buildings. The income and gains of an IREF are not subject to corporation tax or capital gains tax. However, where the profits of the IREF are transferred to certain investors, the IREF is required to apply IREF withholding tax (“IREF WHT”) at a rate of 20 per cent.
Finance Act 2019 introduced an additional suite of anti-avoidance measures for IREFs, resulting in a charge to income tax at the level of the IREF in certain circumstances. These measures were introduced to prevent the use of excessive debt and other payments to reduce distributable profits that would be subject to IREF WHT.
There are exemptions from IREF WHT for certain Irish and non-resident investors, for example, where an investor is a domestic or EU/EEA equivalent pension scheme, investment fund or a life assurance company. These categories of investors are generally associated with collective, widely held investment.
I am advised by Revenue that it is not possible to quantify the revenue that would be raised if these categories of investors are not considered exempt as a breakdown of the IREF taxable amount between taxable and exempt investors is not readily available.
In relation to the Deputy’s question regarding the revenue that would be raised by applying an entity level tax on IREFs at a rate of 1% of total value of the assets held, Revenue has published information in Table 31 of a Revenue research report titled “Corporation Tax – 2025 Payments and 2024 Returns” which shows the value of assets reported by IREFs total €26.8bn for accounting periods ending in 2024. If an entity level tax of 1% was applied to this value, the estimated yield is €268m. The research report is available on the Revenue website at: www.revenue.ie/en/corporate/documents/research/ct-analysis-2026.pdf
I am advised by Revenue that due to the small number (less than ten) of Real Estate Investment Trusts (“REITs”) that operate in Ireland and given Revenue’s obligation to maintain the confidentiality of taxpayer information, specific information in relation to the value of assets held cannot be provided.
As publicly listed companies, REITs are required to publish information such as annual accounts online and these may be of assistance to the Deputy.
