Written answers

Thursday, 18 December 2014

Department of Finance

Tax Reliefs Availability

Photo of Terence FlanaganTerence Flanagan (Dublin North East, Independent)
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149. To ask the Minister for Finance the various special executive tax breaks that are available to executives in multinationals; and if he will make a statement on the matter. [49390/14]

Photo of Michael NoonanMichael Noonan (Limerick City, Fine Gael)
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It is assumed that the Deputy is referring to the Special Assignee Relief Programme (SARP). As the Deputy will be aware, my officials, in conjunction with the Revenue Commissioners, conducted a review of SARP in advance of this year's Budget. The review analysed aspects of the scheme such as the background and rationale for the programme and data available from the Revenue Commissioners including the cost and take-up of the programme. In addition, a public consultation and stakeholder meetings were held. A report was written on the review and this has been published on the Department's website. Having considered the outcome of the review and Ireland's need to attract FDI, in the recent Budget I decided to:

- extend and enhance SARP for a further three years until the end of 2017;

- Remove the upper salary threshold to encourage senior decision makers to come to Ireland;

- Amend the residency requirement to only require Irish tax residency. This was proving to be a barrier to individuals in their year of arrival into Ireland, and also for individuals from countries where they are deemed to be permanently tax resident; and

- Reduce the requirement to have been employed abroad by the same employer for 12 months prior to being assigned to Ireland to 6 months in order to align with recent changes to employment permit legislation.

- I believe these measures are a positive step forward as part of a range of measures, forming the Roadmap to secure Ireland's place as a destination for the best and most successful companies in the world.

The scheme now operates as follows:

- An exemption from income tax on 30% of salary in excess of €75,000 is provided for employees that are assigned for a minimum of 1 year. The exemption is available for a maximum of 5 years. The scheme will operate through the PAYE system as a deduction from income tax, but USC will continue to be payable on the full income amount. Social Insurance will also be payable where the individual is not liable to it in their home country.

- The assignee must have been employed by the company in a country with which Ireland has a Double Taxation Agreement (DTA) or a Tax Information Exchange Agreement (TIEA) immediately prior to the assignment to Ireland, and must be tax resident in Ireland in the relevant tax year in order to qualify for SARP.

- One trip home per year is allowed tax free, where paid for by the employer. No other day-to-day expenses will be permitted free of income tax. In recognition of differences in curriculums taught and languages spoken by the assignee and/or their children being brought to Ireland, vouched school fees of up to €5,000 per annum per child where paid for by the employer on behalf of an employee are allowed free of benefit-in-kind taxation.

- Share-based remuneration can also qualify for the exemption and there are no restrictions on where the income can be remitted.

- Any assignee that avails of the scheme up until 31 December 2017 will have access to the relief for the period of their assignment, up to the maximum 5 years.

The Deputy will be aware that this Government is committed to job creation. A key part of this focus is to attract FDI into Ireland. It is important that Ireland can attract and retain the decision makers and senior executives who make such investment decisions. I believe that this measure will support the export led recovery in the economy by maintaining Ireland's competitiveness for attracting FDI. The Deputy will be aware of the job creation that results from such investments.

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