Peadar Tóibín (Meath West, Sinn Fein)
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119. To ask the Minister for Finance the annual revenue that would be raised from tax on spread betting, involving shares and stock options gains taxed at 20%. [25294/15]

Michael Noonan (Limerick City, Fine Gael)
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In relation to spread betting on financial instruments, the Central Bank authorises firms under the Markets in Financial Instruments Directive (MiFID) to provide investment services which can include spread betting services.  The Central Bank has informed me that there are currently no MiFID authorised spread betting firms supervised by the Central Bank. Accordingly, there is no basis for compiling an estimate of the gain to the Exchequer that would arise from the tax outlined by Deputy.

Peadar Tóibín (Meath West, Sinn Fein)
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120. To ask the Minister for Finance the annual revenue that would be raised from a tax on Pay Related Social Insurance of 5% and 10.75% on all stocks awards, Approved Profit Sharing Schemes and share option exercises by employees. [25295/15]

Michael Noonan (Limerick City, Fine Gael)
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I am informed by the Revenue Commissioners that the information in respect of stock awards, Approved Profit Sharing Schemes and share options exercised by employees is not captured in such a way as to provide a basis for compiling an estimate of the gain to the Exchequer that would arise from a tax or Pay Related Social Insurance charge outlined by the Deputy.  Accordingly, the information requested by the Deputy is not available.

Peadar Tóibín (Meath West, Sinn Fein)
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121. To ask the Minister for Finance the annual revenue that would be raised by applying a minimum of 20% tax to all Real Estate Investment Trust income. [25296/15]

Peadar Tóibín (Meath West, Sinn Fein)
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122. To ask the Minister for Finance the annual revenue that would be raised by applying a minimum of 25% tax to all Real Estate Investment Trust capital gains. [25297/15]

Peadar Tóibín (Meath West, Sinn Fein)
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123. To ask the Minister for Finance the annual revenue that would be raised if the non-resident withholding tax exemption was removed for Real Estate Investment Trusts. [25298/15]

Michael Noonan (Limerick City, Fine Gael)
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I propose to take Questions Nos. 121 to 123, inclusive, together.

I am informed by the Revenue Commissioners that there are currently four Real Estate Investment Trusts ("REITs") established and operating in Ireland.

The function of the REIT framework is not to provide an overall tax exemption, but rather to facilitate collective investment in rental property by removing a double layer of taxation which would otherwise apply to property investment via a corporate vehicle. As such, the estimated cost attached to REITs relates not to an exemption from tax, but rather to the move from direct taxation of rental income in the hands of investors, to the taxation of dividends distributed to investors from REIT profits arising from that rental income.  The REIT legislation requires that 85% of all property income profits be distributed annually to shareholders. 

In general, the trading profits of companies in Ireland are subject to Corporation Tax at 12.5%. Rental profits of companies are subject to Corporation Tax at 25%. Rental profits arising in a REIT are exempt from Corporation Tax. However, profits from any other activities are subject to Corporation Tax in the normal way.

In answer to the question as to how much annual revenue would be raised by applying a minimum rate of Income Tax of 20% to all REIT income, REITs are publically listed companies, meaning their Financial Statements are publically available, but the specific figures required to calculate their rental profit (the portion of profit that is exempt) is not necessarily available in these public documents. For reasons of taxpayer confidentiality, it would be inappropriate for me to comment on specific details of rental profit, if any, of the limited number of REITS currently operating in Ireland.  

In answer to the question as to how much annual revenue would be raised by applying a minimum rate of tax of 25% to all REIT Capital Gains, REITs are investment vehicles that are specifically designed to hold rental investment property.  They are focused on long-term holding of income-producing property.  They are not designed specifically to undertake development activities, or as a vehicle for short-term speculative gains. There is an exemption from Capital Gains Tax for a REIT on the sale of properties from its property rental business. It is not possible to predict when (or if) a REIT may sell some (or all) of its rental property portfolio or to predict what gain, if any, may arise on such hypothetical future sales.

In answer to the question as to how much annual revenue would be raised if the non-resident withholding tax exemption was removed for REITs, I can confirm there is no such exemption. In general, distributions (i.e. payments) from Irish resident companies to Irish shareholders are subject to Dividend Withholding Tax ("DWT"). Payments made to non-resident shareholders are generally exempt from  DWT. There is no exemption from DWT for payments made from a REIT from profits arising from its property rental business to non-resident shareholders, as the general DWT exemption does not apply in such circumstances. However, non-resident investors who are resident in countries with which Ireland has a double taxation agreement (DTA) may be able to reclaim some of the DWT, if the relevant DTA permits. Non-resident investors who are resident in countries with which Ireland does not have a DTA will suffer DWT on the full amount of the distribution.