Mr. Niall Cody:

One of the issues is that in certain cases family members of high wealth individuals are brought in. Sometimes the only reason they are brought in is, essentially, there is a liability for capital acquisitions or capital gains tax. They do not have an income in their own right, but they may be the beneficiary of a gift. A total of 25 of the 83 individuals were family members who did not have an income but were included in the case base because they were part of the family group. A total of 21 individuals were non-resident and non-domiciled; therefore, they were only subject to income tax on Irish sourced income or income remitted in Ireland. They were included because they had significant links with Ireland, but they were not generating an income in Ireland. A total of 22 high wealth individuals in taxpayer specific circumstances were impacted on significantly by the downturn. This category would not have been significant if the crash had not happened in 2009 and 2010. Some of them have ended up bankrupt and are no longer high wealth individuals. However, some of them will recover. A total of 15 high wealth individuals had a significant release of capital allowances or losses. In the material we sent to the committee we included a copy of a recent report on the high income earner restriction. There are reliefs that are restricted if an individual's income is in excess of €400,000 and he or she must at least pay at a 30% effective rate. If relief is restricted in one year, he or she can carry forward the part that is unused; therefore, it is pent up. It is like the lost relief discussions we had on corporation tax. People carry forward certain losses and reliefs which impacts on their income in the year in question. The 83 individuals have valid reasons. They are set out in the Comptroller and Auditor General's report, but, again, in some way it becomes a much better headline.