Róisín Shortall (Dublin North West, Labour)
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Question 145: To ask the Minister for Finance the further details on measures announced in budget 2010 with respect to the treatment of non-residents for tax purposes; the revenue he expects these new measures to raise in 2010 and in a full year; the number of non-residents for tax purposes he expects these new measures to affect; if he expects these new measures to bring about behavioural changes or to induce such non-residents to take up Irish domicile for tax purposes; and if he will make a statement on the matter. [5330/10]

Brian Lenihan Jnr (Dublin West, Fianna Fail)
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I assume that the measure to which the Deputy refers is the domicile levy which I announced in budget 2010, full details of which will be announced in the Finance Bill on Thursday. The levy of €200,000 will apply to Irish nationals and domiciled individuals whose worldwide income exceeds €1 million and whose Irish-located property is worth greater than €5 million.

I am informed by Revenue that for the 2007 tax year (the latest year for which figures are available), 7,228 non-resident individuals filed Irish tax returns in respect of their Irish-source income or income derived from working here. The total amount of tax paid by these persons was c €43 million. For the 2006 tax year, 5,993 non-resident individuals filed Irish tax returns in respect of their Irish-source income or income derived from working here. The total amount of tax paid by these persons was €44.5 million.

The equivalent figures for 2008 are not yet available. Returns for 2008 were due by 31 October 2009 or, in the case of returns made on ROS (Revenue Online System), by 16 November 2009. The data capture of information of these returns is currently under way and when completed will facilitate the compilation of statistics for 2008.

Many of the individuals who declare on their tax return that they are non-resident in the State do not have an Irish address. Many of these non-residents are foreign nationals or have a foreign domicile; and many of the non-resident Irish citizens or Irish domiciled individuals included in this figure may have become non-resident for reasons unrelated to taxation, but have retained Irish investments (such as rental property). It is therefore not possible to estimate the number of non-residents that this measure will affect.

The policy objective behind this levy is to ensure that every wealthy Irish domiciled individual who pays little or no income tax, makes a contribution to the State, particularly during these difficult economic times. Behavioural change can occur for many reasons and it would be impossible to predict any such changes which may occur due to the implementation of this levy.

Domicile is a concept of general law which means, broadly speaking, the place an individual regards as her/his permanent home. Changing domicile is not a straightforward matter and I do not know whether individuals will attempt to acquire Irish domicile because of the introduction of the domicile levy.