Catheolr1eech Chainnen

Ms. Marpret Falsey, Committee Secretariat, Committee of Public Accounts, Lelnster House, Dublin2.

14 November 2018

Dear Margaret,

Revenue a cmi agus Custalm na hEimmn Irish Tax end l"ustoms

Olftg ne gColmlsln6frf loncalm CBISlean Btlalle A1ha Cllath Belle Atha Cllath 2 002 F342 Bra

www.revenue.le

Dfflce of the Revenue Commissioners Dublin castle Dub0n2 D02F342 Ireland

I refer to your letter of 9 November to Niall Cody, Revenue Chairman, inviting attendance at a meeting

to assist the Committee in Its examination of the Revenue Vote Appropriation Accounts 2017; along

with Chapters 17, 18, and 19, of the 2017 Annual Report of the Comptroller and Auditor General.

As requested, I enclose a copy of the Chairman's opening statement to the Committee along with

additional briefing material as follows:

(1) A note on recent changes to Revenue's operational structure (Annex 1};

(2) Slideshow of photographs of the Illegal cigarette factory discovered and dismantled In a

Revenue-led operation in Co. Louth, in March 2018 (Annex 2);

(3) Revenue documents In relation to reviews of the HWI criterion In 2007 and 2015 and a

summary note on Revenue participation In OECD work group leading to the 2009 OECD

Report Engaging w;th High Net Worth Individuals on Tax Compliance (Annex 3);

(4) Revenue report 'Analysis of High Income Individuals' Restrict/on 2016' (Annex 4).

The Chairman will be accompanied by Principal Officers Michael Gilligan, Criminal Investigations; Ruth

Fennessy, High Wealth Individuals; Keith Walsh, Statistics and Economic Research; and Clare Omelia,

Liaison to the Office of the Comptroller & Auditor General and the Committee.

T: +35318585910 F: +35316794145

chelnnenaofflceOrevenua.re

Revenue a Cain agus Custaim na hE~ann lct:;h Ta;{ and. {\t::tom::i www.revenue.le

With the permission of the Committee, Tom Dowling, Assistant Principal, Corporate Services Division;

Leeann O'Kelly, Senior Press Officer; and Finbarr Demoney, Assistant Principal will attend in the Public

Gallery.

If you require any further information please do not hesitate to contact me.

Yours sincerely,

Clare Omelia

Principal Officer

1

Revenue Structure Changes

Note for information of Public Accounts Committee

November 2018

1. We continue to develop Revenue’s structures to ensure that we optimise the alignment of our resources with risk

and deliver a high-quality service to support taxpayer compliance. As outlined in our statement of Strategy 2017 -

2019, we want to ensure our structure accommodates and reflects changes in our customer base, the evolving

national and international tax and customs environment, and the impact of significant changes for tax

administration such as the PAYE Modernisation programme to manage risks. For example, in 2015 Revenue

established a new International Tax Division in order to better manage risks relating to international corporate tax

planning.

2. During 2018, we have been further developing our organisational structure and we are now moving from a single

Large Cases Division and the four geographically based Regions (Border Midland West Region, Dublin Region,

East South-East Region and South West Region) to a new structure that is based on a nationally segmented

customer base. Five new national Divisions are built around the following customer segments:

Large Corporates Division - dealing with the largest companies with Irish turnover greater than €190m and/or

total tax and duty payments greater than €18m;

High Wealth Individuals Division - dealing with high wealth individuals with net assets greater than €50

million or non-residents with substantial economic activity in Ireland. This Division also deals with pensions and

tax avoidance issues;

Medium Enterprises Division - dealing with large businesses and wealthy/high income individuals below the

thresholds for Large Corporates Division and High Wealth Individuals Divisions. This includes cases with

turnover in the State greater than €3m and less than €190m or with turnover in the State greater than €1m and

less than €3m where the entity has more than 100 employees;

Business Division – dealing with business taxpayers not in the categories above;

Personal Division - dealing with all personal or non-trading taxpayers as well as not-for-profit organisations.

This Division also has specialist responsibility for Stamp Duty and Local Property Tax.

2

3. As part of our realignment, and within the context of our Workforce Planning framework, additional resources are

being assigned to manage the risks in larger cases, including high wealth individuals. In total, it is envisaged that

the resources that will be assigned to Large Cases Divisions and Medium Enterprises Division will increase from

410 to 730.

4. Every taxpayer is now managed by Revenue, from a service and compliance standpoint, by one of the new

nationally based Divisions outlined above. The only impact for the purposes of a taxpayer’s engagement with

Revenue is that in certain instances, new teams or new individuals will be looking after that engagement on the

Revenue side.

5. The attached appendix provides a high-level picture of Revenue’s structure before and after realignment,

illustrating the allocation of our resources relative to net tax collections.

3

Appendix

Note: Much of the tax collection in respect of PAYE taxpayers in the Personal Division is submitted by employers and is reflected in the net collections percentages in the Business, Medium Enterprises and Large Corporates Divisions

Note: Local Property Tax (LPT) has been excluded from this illustration as the resource allocation to LPT has not

been changed by realignment

ANNEX 3

Relevant HWI extracts from the ‘LCD Case Base’ paper provided to the MAC

Meeting of 8 October 2015 Summary of Recommendations

Current LCD criteria for High Wealth Individuals [HWI] to remain at €50 million Individuals identified as meeting current LCD HWI criteria from rich list to be transferred into LCD Individuals identified as no longer meeting current LCD HWI criteria to be transferred to Regions/Tier

2 All trusts, partnerships, investment vehicles and offshore companies associated with a HWI to be

managed in LCD along with HWI

Constitution of LCD Case Base if above recommendations accepted

HWIs

545

Current LCD Criteria

Companies with turnover greater than €162m or tax payments greater than €16m per annum and

individuals with net assets greater than €50m (family members with lower incomes may also be

included) or non-residents with substantial economic interests in Ireland.

ANALYSIS OF LCD CASE BASE BASED ON CRITERIA

Year Criteria Case Base Size

2003 (on set up) Individuals Income > 1.3m or Net

Assets > €50m

360 HWIs

Current Individual Net Assets > €50m

(Indexing up to €1.6m & €62m was

recommended but not implemented)

485 HWIs

2015 Individual Net Assets > €50m 545 HWIs

HIGH WEALTH INDIVIDUALS

Following a review of the most recent published rich list, 80 new individuals meet LCD criteria and

need to be brought into LCD and some 20 individuals to be transferred out. It may be that some of

these cases to be transferred in or out of LCD may have open interventions. It is recommended that the

normal rule of only transferring “clean” cases in/out of LCD be relaxed in order to facilitate an

expedient once-off exchange of cases. It is recommended that cases for transfer between LCD and the

Regions be moved notwithstanding that an AQ/PI is open and that cases with an open investigation,

audit or appeal be transferred when the intervention is concluded.

Current LCD Case Base

(Individuals)

Number of Individuals that

no longer meet LCD criteria

to go to Regions

Number of possible

cases that meet LCD

criteria in Regions

New Case

Base of

Individuals

485

(646 cases including

Trusts, Investment

Vehicles etc.)

20 (approx.) 80 545

It is recommended that the Partnerships, Trusts, offshore companies and Investment Vehicles

associated with a HWI should be managed in conjunction with the HWI in LCD/Tier 2 as appropriate.

ANNEX 3

LCD Case Base

Companies/ Groups managed in LCD Numbers Comment

1 Large companies or groups with

turnover greater than €162m or

total tax paid greater than €16m

630 Groups

13,000

companies approx.

The directors/owner/shareholders of

any company are not taken into the

LCD case base unless they are a HWI

in their own right

Individuals managed in LCD Numbers Exceptions (not taken into LCD)

Individuals with net assets

greater than €50m

485 Individuals Companies which the individual owns/part-

owns/has shareholding in/or director of

remains with the geographical district of the

company Note: If company meets LCD

criteria in its own right, it will be managed in

the appropriate sector of LCD

ANNEX 3

Relevant HWI extracts from the ‘Review LCD Case Base’ paper provided to the

MAC Meeting of 13 December 2007 Background: At detailed design stage the MAC decided that LCD would deal with – Large corporates with a turnover greater than €150m or total tax payments greater than

€13m, and High net worth individuals with net assets over €50m / income over €1.3m and non-

residents with substantial economic interests in Ireland. The 2002 MAC decision resulted in an LCD case base of c.370 large corporates and 360 HWIs. Review of LCD Case Base: In 2007 LCD initiated a review of its case base and related issues. This review revealed that there are – 21 individuals with IT greater than €1.3m being dealt with by the Regions.

Recommendations: That the 2002 LCD case admission criteria remain unchanged and that those non-public

sector cases that meet LCD case criteria be taken in by LCD. That discussions be held with the Regions to manage the transfer of these cases to LCD

and to establish stronger linkages between LCD and the Regions in regard to the compliance management of wider groups of large cases within sectors.

ANNEX 3

Summary note on Revenue participation in work group leading to

2009 OECD Report Engaging with High Net Worth Individuals on Tax Compliance

In 2008/9 Revenue participated in an OECD work group consisting of 14 countries; Australia,

Canada, Ireland, Italy, France, Germany, Japan, Mexico, the Netherlands, New Zealand,

Norway, South Africa, the United Kingdom and the United States of America, with

Switzerland acting as an observer.

The purpose of the project was to improve the understanding by tax administrations of the

High Net Worth Individuals (HNWI) taxpayer segment and consider response strategies to

the challenges presented in this.

The group recognised that different terms are used to refer to the top taxpayer segment (e.g.

wealth owners, high wealth individuals, high net worth individuals etc). The paper used the

term “High Net Worth Individuals” (HNWI) broadly to refer to taxpayers at the top of the

wealth or income scale but did not attempt to otherwise define the term.

Thresholds used for domestic taxation purposes were found to differ from country to country,

and to variously refer to wealth, income, and combinations of income or wealth. HNWI

definitions were found to also include other factors such as complexity of the taxpayer’s

affairs.

The group recognised that questions relating to such factors and thresholds are necessarily

decided at domestic level and that any implementation of recommendations from the project

would have to be implemented in the context of what is most appropriate in the circumstances

of each country.

The Report identified four considerations that justify a focus on HNWIs:

1. Complexity – complex business arrangements with wealth spread across many

closely held companies, partnerships, and trusts

2. Contribution – pay a large proportion of taxes

3. Opportunity – access to sophisticated tax advice including aggressive tax avoidance

4. Integrity – important to demonstrate tax system is fair and compliance strategy

applies equally to HNWI’s who attract media & public attention.

The Report was divided into four parts:

Part 1 – The Environment and the Risks - describes the HNWI segment, the tax

environment for the segment, the tax risks within the segment and the market drivers

& the supply chain for aggressive tax planning.

Part 2 – General Strategies to Counter Aggressive Tax Planning by HNWIs –

including use of information/intelligence, staff from the private sector, international

co-operation and communication strategies. It also looks at Demand, Product and

Supply focused strategies.

Part 3 – Organisational Strategies for Dealing with Tax Risk posed by HNWIs –

identifying the segment, resources, staff skills and roles & responsibilities.

Part 4 – Co-operative Strategies – considers aspects of different co-operative

compliance approaches including dedicated contact point, individual rulings, product

rulings, civil penalty protection for full disclosure and ways to deal with voluntary

disclosure for past non-compliance.

ANNEX 3

The Report concluded that marketed schemes are used more by those at the lower end of the

wealth spectrum while bespoke schemes are used by those at the upper end; and that focusing

resources on HNWIs can achieve significant improvement in compliance.

The Report made five main recommendations:

Understand the risks posed by the HNWI sector

Establish an appropriate structure to deal with HNWI’s in the Revenue

Administration

Improve international co-operation

Have an appropriate legislative framework targeted at aggressive tax planning risks

and very important to have a holistic approach rather than having isolated strategies

Explore the concept of co-operative compliance for HNWIs.

September 2018

Statistics & Economic Research Branch

Analysis of High Income

Individuals’ Restriction 2016

Analysis of High Income

Individuals’ Restriction 2016

Statistics & Economic Research Branch

Any queries in relation to the figures in this report can be

directed to statistics@revenue.ie.

1 Statistics & Economic Research Branch

1 Background

The 2006 and 2007 Finance Acts introduced, with effect from 1 January 2007, measures

to limit the use of certain tax reliefs and exemptions (known as “specified reliefs”) by

high-income individuals who, by means of the cumulative use of various tax incentives,

had in previous years the potential to substantially reduce their tax liabilities.

The overall objective is to ensure that, from 2007, individuals with an adjusted income of

€500,000 or more (where the full restriction applied) pay an effective rate of Income Tax

of approximately 20 per cent on a combination of adjusted income and ring-fenced

income.1 The restriction began to apply where an individual’s adjusted income exceeded

€250,000 and the full restriction applied where an individual had adjusted income of

€500,000 or more.

The 2010 Finance Act introduced further limitations on the use of specified reliefs, with

effect from 1 January 2010. These limitations are designed to ensure that individuals with

an adjusted income level of €400,000 or more (where the full restriction applies) pay an

effective rate of Income Tax of approximately 30 per cent on a combination of adjusted

income and ring-fenced income. In addition, the adjusted income on which the restriction

begins to apply was reduced to €125,000.

This report relates to the use of specified reliefs by high-income individuals who are

subject to the restriction in the tax year 2016. Other high-income individuals are subject

to the normal tax rules. Reports relating to previous years, as well as statistics on the tax

paid by all individuals, are available on the Revenue website.2

1 Adjusted income for a tax year is the sum of an individual’s taxable income before the restriction is applied plus the aggregate amount of specified reliefs used in the year, less ring-fenced income (income which is normally liable to tax at specific rates regardless of the amounts involved or the individual’s marginal rate of tax, e.g., interest from which DIRT is deducted). 2 Prior year reports are published at https://www.revenue.ie/en/corporate/information-about-revenue/research/statistical-reports/high-income-earners-reports.aspx and Revenue statistics can be found at http://www.revenue.ie/en/about/statistics/index.html.

2 Statistics & Economic Research Branch

2 Results for 2016

Analysis of the application of the high-income individuals’ restriction for the tax year 2016

shows that the objective of achieving an effective rate of Income Tax of approximately 30

per cent for individuals with an adjusted income of €400,000 or more is achieved.

Where adjusted income is less than €400,000, a tapering approach ensured that there is a

graduated application of the restriction, with the effective rate of Income Tax increasing

towards 30 per cent as adjusted income increases towards €400,000.

A summary of how the restriction operated for the tax year 2016, and the specified tax

reliefs covered by the restriction, is included in Annex 1.

A breakdown of the 2016 results showing the effect of the restriction in its tenth year of

operation is set out in Annex 2. These results are based on actual returns received. A

comparison of the outcome for 2007 through to 2016 is set out below.

Year Total Number of Individuals Additional Income Tax

€m

2016 521 38.51

2015 625 47.21

2014 779 54.73

2013 904 60.43

2012 1,050 63.21

2011 1,143 63.60

2010 1,544 80.18

2009 452 38.86

2008 423 39.68

2007 439 39.99

The results for 2016 show that the overall number of individuals who are subject to the

restriction is 521 and that the additional Income Tax yield is €38.51m. Compared to 2015,

this represents a decrease of 104 in the number of individuals and a decrease of €8.7m in

the additional yield from the measure.

Cases where Full Restriction applies – Adjusted Income of €400,000 or more

Table 1A (Annex 2) shows that the 149 high-income individuals with an adjusted income

of €400,000 or more (i.e., where the full restriction applied) pay an average effective

Income Tax rate of 30.1% on the combination of adjusted income and ring-fenced income.

These individuals pay on average 40.9% tax inclusive of Universal Social Charge (USC).

This meets the objective set out for the measure. The additional Income Tax involved is

€25.8 million, representing a 175% increase on the tax that would otherwise have been

3 Statistics & Economic Research Branch

paid if the restriction had not applied. Furthermore, of those 149 individuals, 54 who

would not otherwise have paid Income Tax in 2016 are brought into the tax net.

Table 1B (Annex 2) summarises the distribution of the effective tax rates for the 149

cases with adjusted income of €400,000 or more. It shows that the majority of high-

income individuals within this category fall into the effective Income Tax rate bands of

30% to 35% (94 cases).

Cases where Restriction partly applies – Adjusted Income of up to €400,000

Table 2A (Annex 2) shows that the 372 high-income individuals with an adjusted income

of up to €400,000 (i.e., where the restriction applies on a graduated basis) pay an

average effective Income Tax rate of 19.09% on the combination of adjusted income and

ring-fenced income. These individuals pay on average 28.61% tax inclusive of USC.

The additional Income Tax involved is €12.7 million representing a 242 per cent increase

on the tax that would otherwise have been paid if the restriction had not applied.

Furthermore, of those 372 individuals, 164 individuals who would not otherwise have paid

Income Tax in 2016 are brought into the tax net.

Table 2B (Annex 2) summarises the distribution of the effective Income Tax rates for the

372 cases with adjusted income of up to €400,000. The spread reflects the graduated

nature of the application of the restriction for cases in this category.

Schedule of Declared Use of Reliefs

Table 3 (Annex 2), in relation to each specified relief, shows:

• The overall number of individuals subject to the restriction, who declared that they

used the relief; and

• The total combined amount of the relief declared as used by those individuals.

4 Statistics & Economic Research Branch

Annex 1

Operation of the Restriction in the tax year 2016

The restriction works by limiting the total amount of “specified reliefs” that a high-income

individual can use to reduce his or her tax liability in any one tax year.

In the tax year 2016, the overall objective is to ensure that individuals with an adjusted

income of €400,000 or more would pay an effective rate of tax of approximately 30 per

cent on a combination of adjusted income and ring-fenced income. A graduated

application of the restriction below an adjusted income level of €400,000 would ensure

that the effective rate of tax increases towards 30 per cent as adjusted income increased

towards €400,000.

For the tax year 2016, the restriction applies to an individual where all of the following

criteria applied:

• The adjusted income of the individual for the tax year is equal to or greater than an

Income Threshold Amount which is, in general, €125,000 but is less if the

individual has ring-fenced income (e.g., deposit interest);

• The aggregate of specified reliefs used by the individual for the tax year is equal to

or greater than a Relief Threshold Amount, which is set at €80,000; and

• The aggregate of specified reliefs used by the individual for the tax year is greater

than 20% of the individual’s adjusted income.

In the case of married couples and civil partners who are jointly assessed, application of

the restriction to each spouse or civil partner is determined separately. Therefore, in 2016,

the restriction applies to each individual spouse or civil partner only where the three

circumstances above apply to that spouse or civil partner for that tax year.

Specified Reliefs

Broadly speaking, the reliefs that are restricted include:

• The various sectoral and area-based property tax incentives;

• Certain exemptions (e.g., relating to artists’ income and dividends and distributions

out of certain exempt income);

• Certain investment incentive reliefs such as Business Expansion Scheme (BES),

Relief for investment on significant buildings and gardens and film relief; and

• Relief for interest paid on loans used to acquire an interest in a company or in a

partnership.

5 Statistics & Economic Research Branch

Normal business-related expenses, deductions for capital allowances on plant and

machinery, business-related trading losses and losses from a rental activity that do not

arise from the use of specified reliefs are not restricted. In addition, personal tax credits

are not affected by the restriction.

6 Statistics & Economic Research Branch

Annex 2

Table 1A: Cases with Adjusted Income of €400,000 or more

Range of Adjusted Income

Number of Cases

Income Tax before

Restriction

Income Tax after

Restriction

Additional Income Tax

after application of

Restriction

Average Effective Rate

before application of

Restriction

Average Effective Rate

after application of

Restriction

Tax including USC payable

after Restriction

Average Effective Rate

(including USC) after

application of Restriction

€

Amount Amount Amount Rate Rate Amount Rate

€ € € % % € %

400,000 to 500,000

36 1,186,028 4,934,810 3,748,782 13.7% 29.1% 6,606,786 39.2%

500,001 to 650,000

42 3,244,373 7,085,768 3,841,395 18.9% 30.0% 9,503,891 40.3%

650,001 to 800,000

26 2,383,516 5,799,610 3,416,093 18.3% 30.3% 7,876,445 41.3%

800,001 to 1,000,000

14 1,311,851 3,980,515 2,668,664 13.8% 30.4% 5,433,132 41.5%

1,000,001 to 1,500,000

19 2,503,314 7,568,764 5,065,450 16.4% 31.0% 10,172,221 41.9%

1,500,001 to 2,000,000

≤10 461,682 1,141,289 679,607 26.3% 31.3% 1,474,414 40.4%

Over 2,000,000

≤10 3,611,884 9,952,681 6,340,797 17.8% 31.6% 14,779,889 46.3%

Totals 149 14,702,648 40,463,437 25,760,788 17.0% 30.1% 55,846,778 40.9%

7 Statistics & Economic Research Branch

Table 1B: Effective Income Tax Rates – cases with Adjusted Income of €400,000

or more

Effective Rate Number of Cases % of all Cases

≤15% <10 N/A

>15% ≤25% <10 N/A

>25% ≤30% 52 34.90%

>30% ≤35% 94 63.09%

Above 35% 0 0.00%

Totals 149 100%

Table 1C: Effective Tax Rates – inclusive of USC – cases with Adjusted Income of

€400,000 or more

Effective Rate (Including USC)

Number of Cases % of all Cases

≤30% <10 N/A

>30% ≤35% <10 N/A

>35% ≤40% 57 38.26%

>40% ≤45% 72 48.32%

>45% ≤50% 11 7.38%

>50% ≤55% <10 N/A

Above 55% <10 N/A

Totals 149 100%

Note: Certain items are deductible when arriving at adjusted income (e.g., pension contributions, certain rental capital allowances on plant and machinery, trading losses against other income, etc.) that are not deductible against income on which USC is chargeable. These differences can give rise to taxpayers having effective USC inclusive tax rates on their adjusted income in excess of the top rate of tax plus the top rate of USC.

8 Statistics & Economic Research Branch

Table 2A: Cases with Adjusted Income of up to €400,000

Range of Adjusted Income

Number of Cases

Income Tax before

Restriction

Income Tax after

Restriction

Additional Income Tax

after application of

Restriction

Average Effective Rate

before application of

Restriction

Average Effective Rate

after application of

Restriction

Tax including USC payable

after

Restriction

Average Effective Rate

(including USC) after

application of Restriction

€ Amount Amount Amount Rate Rate Amount Rate

€ € € % % € %

Under 160,000

78 229,433 1,231,175 1,001,742 4.28% 10.24% 2,264,065 19.22%

160,001 to 200,000

84 618,307 2,498,044 1,879,738 7.94% 16.13% 3,950,608 25.55%

200,001 to 250,000

100 1,369,284 4,692,390 3,323,106 9.53% 20.80% 6,835,837 30.37%

250,001 to 325,000

71 1,912,266 5,558,653 3,646,387 12.35% 25.01% 7,738,412 35.03%

325,001 to 399,999

39 1,139,465 4,034,724 2,895,259 11.25% 27.96% 5,428,960 37.77%

Totals

372 5,268,754 18,014,986 12,746,232 9.22% 19.09% 26,217,881 28.61%

9 Statistics & Economic Research Branch

Table 2B: Effective Income Tax Rates – cases with Adjusted Income of up to

€400,000

Effective Rate Number of Cases % of all Cases

≤10% 33 8.87%

>10% ≤15% 68 18.28%

>15% ≤20% 92 24.73%

>20% ≤25% 96 25.81%

>25% ≤30% 83 22.31%

Above 30% 0 0.00%

Totals 372 100%

Table 2C: Effective Tax Rates – inclusive of USC – Adjusted Income of up to

€400,000

Effective Rate (Including USC)

Number of Cases % of all Cases

>0% ≤5% 0 0.00%

>5% ≤10% ≤10 N/A

>10% ≤15% ≤10 N/A

>15% ≤20% 42 11.29%

>20% ≤25% 59 15.86%

>25% ≤30% 93 25.00%

>30% ≤35% 91 24.46%

>35% ≤40% 66 17.74%

>40% ≤45% 11 2.96%

Above 45% 0 0.00%

Totals 372 100%

Note: Certain items are deductible when arriving at adjusted income (e.g., pension contributions, certain rental capital allowances on plant and machinery, trading losses against other income, etc.) that are not deductible against income on which USC is chargeable. These differences can give rise to taxpayers having effective USC inclusive tax rates on their adjusted income in excess of the top rate of tax plus the top rate of USC.

10 Statistics & Economic Research Branch

Table 3 – Schedule of Declared Use of Different Reliefs in accordance with

Schedule 25B of the Taxes Consolidation Act, 1997

Ref Number

Specified Relief

Number of

Cases

Amount of Relief used in 2016 by those affected by

the Restriction €

1/2/3/4

Sect 140, 141, 142 and 143 – dividends and distributions out of exempt income from stallion fees, stud greyhounds, woodlands, patents, certain mines and other mining operations

<10 54,196

5 Sect 195 – Exempt income, profits or gains of artists, writers or composers

<10 243,400

6 Sect 231 – Exempt stallion fees N/A

7 Sect 232 – Exempt woodland income <10 50,231

8 Sect 233 – Exempt stud greyhound fees N/A

9 Sect 234 – Exempt patent royalty income N/A

10/11 Sect 248 and 250 – relief for interest paid on loans to acquire an interest in a company

N/A

12 Sect 253 – relief for interest paid on loans to acquire an interest in a partnership

<10 9,246

13 Sect 272 – writing down allowances in respect of capital expenditure on:

• hotels and holiday camps/cottages 27 7,579,783

• nursing homes, residential units attached to

nursing homes and convalescent homes 17 2,083,149

• hospitals, sports injury clinics and mental health

centres 29 2,635,899

14 Sect 273 – accelerated writing down allowances in respect of certain industrial buildings or structures

<10 854,260

15 Sect 274 – balancing allowances in respect of capital expenditure on:

• hotels and holiday camps/cottages <10 783,560

• nursing homes, residential units attached to

nursing homes and convalescent homes <10 837,641

• hospitals, sports injury clinics and mental health

centres <10 652,754

15A Sect 304(4) – Carry forward of capital allowances (relating to specified reliefs) in trading situations

N/A

15B Sect 305(1) – Set off and carry forward of capital allowances (relating to specified reliefs) in rental situations

<10 936,314

15C

Sect 284 (subject to section 485C(1B) – wear & tear allowances on plant and machinery claimed by a passive trader when leasing the plant and machinery to a manufacturing trade.

N/A

15D 288 (subject to section 485C(1B) – balancing allowances on plant and machinery claimed by a passive trader when leasing the plant and machinery to a manufacturing trade

N/A

16/17

Sect 323 and 324 – Custom House Docks Area: capital allowances for commercial premises and double rent allowance in respect of rent paid for certain business premises

<10 157,946

18/19/20

Sect 331, 332 and 333 – Temple Bar Area: capital allowances for industrial buildings, commercial premises and double rent allowance in respect of rent paid for certain business premises

N/A

21 Sect 341 – Urban Renewal Scheme: capital allowances for industrial buildings

<10 815,235

22 Sect 342 – Urban Renewal Scheme: capital allowances for commercial buildings

14 1,612,747

23 Sect 343 – Enterprise Area: capital allowances for certain buildings

<10 384,258

24 Sect 344 – Multi Story Car Park capital allowances <10 3,582,404

25 Sect 345 - Urban Renewal, Enterprise Area, Multi Story Car Park: double rent allowance in respect of rent paid for certain business premises

<10 2,147,546

26 Sect 352 – Qualifying Resort Area: capital allowances for certain industrial buildings

N/A

27 Sect 353 – Qualifying Resort Area: capital allowances for certain commercial buildings

<10 7,385

11 Statistics & Economic Research Branch

Ref Number

Specified Relief

Number of

Cases

Amount of Relief used in 2016 by those affected by

the Restriction €

28 Sect 354 – Qualifying Resort Area: double rent allowance in respect of rent paid for certain business premises

N/A

29 Sect 372C – Qualifying (Urban) Areas: capital allowances for certain industrial buildings

10 693,315

30 Sect 372D – Qualifying (Urban) Area and Living over the shop scheme: capital allowances for certain commercial buildings

15 2,151,359

31/32 Sect 372M and Sect 372N – Qualifying Rural Areas: capital allowances for certain industrial and commercial buildings

<10 244,319

33/34 Sect 372V and 372W – Park and Ride Scheme: Capital allowances for Park and Ride Facilities and for certain commercial buildings

<10 239,333

35 Sect 372AC – Town Renewal Area: capital allowances for certain industrial buildings

<10 760,413

36 Sect 372AD – Town Renewal Area: capital allowances for

certain commercial buildings 14 1,087,825

36A/36B Sect 372AX and 372AY – Mid Shannon Corridor Tourism Scheme: capital allowances for certain registered holiday camps and tourism infrastructure facilities

<10 32,792

37/38 Sect 372AP and Sect 372AU(1) – Relief for lessors of residential premises (“section 23” type relief, including old schemes)

54 11,544,301

38A Sect 372AAC - Living City Initiative: capital allowances in relation to conversion or refurbishment of certain commercial premises

N/A

39 Sect 381 – Repayment of tax due to losses (arising from use of specified reliefs)

<10 33,186

40 Sect 381 – Repayment of tax due to losses (arising from use of specified reliefs), as extended by Sect 392

<10 140,674

41 Sect 382 – Carry forward of losses (arising from use of specified reliefs) to future years

N/A

42/43/44 Sect 383, Sect 384 and Sect 385 – Relief (arising from use of specified reliefs) for losses under Case IV and Case V and for Terminal losses

44 7,071,522

45 Sect 481 – Relief for investment in Films N/A

46 Sect 482 – Relief for investment on significant buildings and gardens

<10 237,292

47 Sect 485F – Carry forward of excess relief 346 97,808,596

47A Sect 489(2)(a) – Employment and Investment Incentive Scheme 3

N/A

48 Sect 489(3) – BES relief N/A

48A Sect 823A - Deduction for income earned in certain foreign states

<10 27,000

49 Sect 843 – Capital allowances for buildings used for third level education purposes

<10 228,520

50 Sect 843A – Capital allowances for certain child-care facilities

<10 261,324

51 Sect 847A – Donations to certain sports bodies <10 2,500

52 Sec. 848A - Donations to approved bodies4 N/A

53 Paragraph 11 of Schedule 32, Urban Renewal Scheme 1986: Capital allowances for certain commercial premises in designated areas

<10 938,831

54 Paragraph 13 of Schedule 32, Urban Renewal Scheme 1986: Double rent allowances in relation to certain premises in designated areas

<10 191,184

Totals 665 149,122,240

Notes: for publication purposes some categories have been amalgamated; where the number of cases is marked “<10”, this indicates the number is less than 10 but the exact figure is not shown to protect taxpayer confidentiality; “N/A” indicates that the Specified Relief is either unavailable or has not been availed of in the period under review.

3 The combination of section 16 Finance (No. 2) Act 2013 and section 20 Finance Act 2016 mean that an investment made after 15 October 2013 in the EII Scheme is not a specified relief. 4 Relief under section 848A in respect of contributions to “approved bodies” was discontinued for donations made on/after 1 January 2013