Pearse Doherty (Donegal, Sinn Fein)
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27. To ask the Minister for Finance the estimated revenue generated in each of the years 2022, 2023, 2024 and 2025 that were the capital allowances claimed against intangible assets onshored between 2015 and 11 October 2017 capped at the current rate of 80%; and the estimated quantum of capital allowances remaining to be claimed against those assets. [45282/21]

Paschal Donohoe (Dublin Central, Fine Gael)
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The 80% cap on capital allowances for intangible assets was re-introduced in Finance Act 2017 and it applies to all intangible assets on-shored from 11 October 2017. The cap only affects the timing of relief in the form of capital allowances and related interest expenses for intangible assets and does not affect the overall quantum of relief. This is because any amounts restricted in one accounting period (resulting from the cap) would be available for carry forward to a subsequent accounting period, subject to the application of the cap in that period.

I am advised by Revenue that Corporation Tax returns do not record the on-shoring of intangible assets (or the year in which on-shoring occurred). The available information is the amounts of capital allowances claimed in respect of intangible assets.

A tentative estimate of the potential short-term cash-flow benefit that could accrue if intangible assets on-shored between 2015 and 11 October 2017 were subject to the 80% cap has been provided on previous occasions. However, as Revenue anticipate that many of the claims associated with the period 2015 to 2017 are likely to be finishing due to the write down periods for these assets, it is likely that the impact of the suggested cap in the requested years would not be significant. An estimate of allowances remaining to be claimed is not available.