Gerald Nash (Louth, Labour)
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366. To ask the Minister for Finance the yield accrued from the standard rate of the section 627 exit tax charge of 12.5% in 2019 and 2020 respectively in tabular form; and if he will make a statement on the matter. [39929/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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As the Deputy may be aware, the current Exit Tax charge contained in section 627 of the Taxes Consolidation Act, 1997 (TCA 1997) was introduced as part of the transposition of the EU Anti-Tax Avoidance Directives (ATAD). The ATAD Exit Tax completely replaced the old exit tax regime, which was designed to counter a specific type of avoidance, and took effect from October 2018. Information in respect of any exit tax payable under the new regime is required to be be separately recorded on corporation tax returns for 2019 and subsequent years.

I am advised by Revenue that the available data for 2019 does not show any disposals giving rise to a charge to exit tax under section 627 TCA 1997. Information in respect of 2020 corporation tax returns is not yet available because all the returns are not yet filed and analysed. As the Deputy is aware, a company's corporation tax return filing date is determined by its accounting period end date. Companies with an accounting period end date of 31 December 2020 are not required to file their 2020 corporation tax return until 23 September 2021.

Gerald Nash (Louth, Labour)
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367. To ask the Minister for Finance the estimated additional yield to the Exchequer from a 0.1% and a 1% increase in the stamp duty applicable to transfers of shares, stocks and marketable securities in Irish incorporated companies; and if he will make a statement on the matter. [39930/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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I am advised by Revenue that the ‘Ready Reckoner’, which is available at www.revenue.ie/en/corporate/documents/statistics/ready-reckoner.pdf, shows on page 20 the estimated yield from changes to the rate of Stamp Duty on shares. The current rate of Stamp Duty on the transfers of shares is 1% and the proposed increases can be derived on a pro rata basis from the published table.

I am further advised by Revenue that as Stamp Duty liabilities in respect of the transfer of shares are not returned separately by place of incorporation, information specifically in relation to Irish incorporated companies is not available.

Gerald Nash (Louth, Labour)
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368. To ask the Minister for Finance the estimated cost to the Exchequer of reducing the interest on deferral of local property tax payments to an annual rate of 0.5% based on the latest available data in tabular form; and if he will make a statement on the matter. [39931/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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The interest rate for Deferrals of Local Property Tax (LPT) in respect of the current ‘Valuation Period’ (2013 to 2021) is 4%. The table below, in columns 1 to 4, sets out the number, value and accrued interest to date on Deferrals taken out each year from 2013 to 2020 (Deferrals for 2021 won’t attract interest if payment is made this year). Columns 5 and 6 in the table show the impact if the interest rate for the years in question was set at 0.5%.

The interest rate to be applied to Deferrals of LPT in the new ‘Valuation Period’ (2022 to 2025) is reduced to 3%, as provided for in the Finance (Local Property Tax) (Amendment) Act 2021.

Gerald Nash (Louth, Labour)
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369. To ask the Minister for Finance the estimated additional yield that would accrue from a dividend withholding tax rate of 41% on all dividends paid by REITs and IREF respectively in tabular form; and if he will make a statement on the matter. [39932/21]

Pearse Doherty (Donegal, Sinn Fein)
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448. To ask the Minister for Finance the estimated revenue that would be generated in 2022 by increasing the rate of dividend withholding tax for REITs and IREFs to 33%. [41357/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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I propose to take Questions Nos. 369 and 448 together.

Real Estate Investment Trusts (REITs) are corporate entities, and as such pay dividends to their shareholders. Dividend Withholding Tax (DWT), which is charged at 25%, must be applied to REIT distributions, other than those distributed to certain limited classes of investors such as pension funds and charities as they are more generally exempt from tax.

Irish Real Estate Funds (IREFs) are fund vehicles and therefore are not subject to DWT. They are instead subject to a 20% withholding tax on distributions to non-resident investors. Furthermore, Irish resident individuals/corporates are subject to investment undertakings tax. Certain categories of investors such as pension funds, life assurance companies and other collective investment undertakings are generally exempt from having IREF withholding tax applied provided the appropriate declarations are in place.

The yield from changes in the rates of withholding taxes on REITs and IREFs would be dependent on the level of future distributions by these entities. As such there is no basis available to provide an accurate estimate of these future distributions.

However, the Deputies may be interested to note the information published on IREFs in Table 18 of the Revenue research report which is available at www.revenue.ie/en/corporate/documents/research/ct-analysis-2021.pdf, which includes information for 2017-2019, based on returns filed.

Gerald Nash (Louth, Labour)
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370. To ask the Minister for Finance the cost to the Exchequer of claims for each individual item of allowable expenses against rental income based on the most recent data in tabular form; the cost to the Exchequer of claims from non-residential landlords; and if he will make a statement on the matter. [39934/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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I am advised by Revenue that as tax liability is calculated based on the combination of all incomes, reliefs, credits and deductions, it is not possible to provide an exact tax cost for the items outlined. To estimate tentative costs, it is possible to look at the amounts claimed under each item and apply an average marginal rate of tax. The average marginal rate of tax is the average rate across all taxpayer types and is not confined to those with a rental income.

I am advised by Revenue that 2018 represents the latest year for which complete data are available.

The table below sets out the estimated 2018 tax cost of the allowable expenses against rental income, separated into each individual item as declared on tax returns, and separated into residential and non-residential properties.

Gerald Nash (Louth, Labour)
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371. To ask the Minister for Finance the estimated savings to the Exchequer from eliminating excise forgone on auto-diesel, marked gas oil, kerosene and fuel oil based on the latest available data in tabular form; the estimated savings to the Exchequer from ending the diesel rebate scheme and excise forgone on commercial sea navigation; and if he will make a statement on the matter. [39935/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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It is assumed that the Deputy is referring to setting the level of Excise for auto-diesel, marked gas oil, kerosene, and fuel oil as being equal to that for Petrol.

I am advised by Revenue that the estimated savings to the Exchequer from eliminating Excise forgone on auto-diesel, marked gas oil, kerosene, and fuel oil are shown in the table below.

Also included in the table are the savings from ending the Diesel Rebate Scheme (DRS), and the relief for Commercial Sea Navigation.

The estimates are based on 2020 data.

Gerald Nash (Louth, Labour)
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372. To ask the Minister for Finance the estimated yield to the Exchequer from an annual levy on insurance firm profits at a rate of 1%; and if he will make a statement on the matter. [39937/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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I am advised by Revenue that the trading profits of companies in Ireland are generally taxed at the standard Corporation Tax rate of 12.5 per cent. Some of the main features of the current Corporation Tax regime are its simplicity and that it applies to a broad base.

Changing this rate (or imposing additional levies on corporate profits) would involve increased complexity and could change the attractiveness of Ireland's corporate tax offering. It is not possible to accurately predict the effect that changes to the rate would have on the behaviour and decisions of large, multinational companies. This uncertainty prevents a reliable estimate being made of any yield that may accrue to the Exchequer.

Notwithstanding the above, I am further advised by Revenue that on a straightforward mathematical basis and assuming no behavioural changes by companies, the potential yield from imposing a 1% levy on the profits of insurance firms, is tentatively estimated to be in the region of €48 million in a year.

Gerald Nash (Louth, Labour)
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374. To ask the Minister for Finance the cost to the Exchequer of the removal and relocation expenses in 2018 and 2019 respectively in tabular form; and if he will make a statement on the matter. [39939/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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I am advised by Revenue that employers who pay employees’ removal and relocation expenses are required to keep relevant records for a period of at least 6 years. However, as there is no reporting requirement in relation to this provision, there are no data available on which to estimate the tax foregone.

Gerald Nash (Louth, Labour)
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375. To ask the Minister for Finance the estimated yield for an increase in the 12.5% rate for trading profits by either 0.5% or 1% and to increase the 25% rate for non-trading profits by 1%, 2% or 5%; and if he will make a statement on the matter. [39941/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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On a straightforward, mathematical basis there would be a theoretical yield from increasing the corporation tax rates for trading and non-trading income. However, the Economic and Social Research Institute (ESRI) reports that research from both the United States and Europe suggests that foreign direct investment (FDI) and the decisions of multinationals to locate in Ireland are highly sensitive to rates of corporation tax. Therefore, increasing the corporation tax rates would likely lead to lower levels of economic activity, behavioural changes in the locational decisions of multinational companies and employment in the multinational sector.

As a result of the difficulty of predicting and quantifying these impacts, particularly in the current economic climate, it is not possible to accurately or robustly estimate the potential yield from the increases proposed by the Deputy. I would note however that ESRI research in 2011 estimated that reducingIreland’s corporation tax rate from 40% in 1994 to 12.5% in 2003 added almost 4% to the level of economic output in 2005 and around €2 billion in corporation tax revenues.

Furthermore, while corporation tax is statutorily levied on the profits of businesses, the ESRI states that researchers have concluded that a large share of the burden is likely to be borne by workers in the form of lower wages. This can arise from companies deciding to invest less, leading to lower capital and lower labour productivity and wages. As the ESRI found that small and medium enterprises (SMEs) predominantly finance their investments in fixed assets, intangible assets and staff through internal funds, raising the rates of corporation tax would hamper their ability to invest and grow.

Gerald Nash (Louth, Labour)
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376. To ask the Minister for Finance the estimated gains that would accrue to the Exchequer over the years 2021 to 2025 from the introduction of a minimum effective corporation tax rate of 12.5% and 15% respectively; and if he will make a statement on the matter. [39942/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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The trading profits of companies in Ireland are generally taxed at the standard corporation tax rate of 12.5%. Some of the main features of the current corporation tax regime are its transparency and that it applies to a broad base. Analysis undertaken by the Department of Finance, co-authored by an independent academic, a separate report undertaken by the Comptroller & Auditor General (C&AG), and Revenue’s annual analysis of corporation tax payments and returns, all confirm that the effective rate of corporation tax, using the most appropriate methodology, paid by corporations in Ireland is between 10% and 11%. While this percentage is lower than the 12.5% headline rate, this can be attributed to the availability of the small number of targeted tax measures that are provided for in legislation and may only be availed of where the legislative criteria for relief are satisfied. Compliance with these tax obligations and eligibility for tax reliefs are monitored by Revenue on an ongoing basis.

Notwithstanding the above, it should also be noted that seeking to impose a minimum effective tax rate would involve increased complexity and could change the attractiveness of Ireland’s corporate tax regime. It is not possible to accurately predict how the imposition of a minimum effective tax rate would affect the behaviour and investment decisions of multinational or domestic companies. Therefore, it is not possible to accurately or robustly estimate the potential Exchequer impact of these proposals.

The Deputy will also be aware that Ireland has expressed broad support for the OECD Inclusive Framework’s proposed two-pillar solution to address tax challenges arising from digitalisation and globalisation, but have expressed reservations in particular about the proposed global minimum effective tax rate of “at least 15%”. Given the importance of the OECD proposals, I have invited views through a public consultation and the consultation period will run until 10 September 2021.