Written answers

Wednesday, 18 September 2024

Photo of Róisín ShortallRóisín Shortall (Dublin North West, Social Democrats)
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189. To ask the Minister for Finance to provide a list of the companies who benefited from the 100 percent cap on capital allowances for intangible assets from 2015 to 2017 (details supplied), in tabular form; and if he will make a statement on the matter. [36660/24]

Photo of Róisín ShortallRóisín Shortall (Dublin North West, Social Democrats)
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190. To ask the Minister for Finance the total revenue generated from the capital allowances for intangible assets scheme in each year since 2010, and to date in 2024, in tabular form. [36661/24]

Photo of Jack ChambersJack Chambers (Dublin West, Fianna Fail)
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I propose to take Questions Nos. 189 and 190 together.

Section 291A of the Taxes Consolidation Act 1997 (TCA) provides relief in the form of capital allowances against trading income on the capital expenditure incurred by companies on the provision of intangible assets for the purposes of a trade. The scheme applies to a broad range of intangible assets (e.g. patents, copyright, trademarks, know-how), both acquired and internally developed, which are recognised as such under generally accepted accounting standards and which are listed as a “specified intangible asset” in the section. Intellectual property (IP) allowances may only be deducted from income generated by those assets.

When initially introduced, an 80% cap applied to the amount of profits of a relevant trade that could be sheltered by IP capital allowances in an accounting period. The cap was removed in Finance Act 2014 to bring the tax treatment of intangible assets into line with the tax treatment of other assets, and of similar assets in other jurisdictions. However, the cap was subsequently re-introduced in Finance Act 2017, in respect of expenditure on intangible assets on or after 11 October 2017, in response to a recommendation in the Coffey Review, with the aim of smoothing corporation tax receipts and helping to support their sustainability. The 80% cap does not affect the overall quantum of relief, it merely extends the period over which that relief is granted.

In relation to question seeking a list of companies who availed of the relief in the period from 2014 – 2017 it is not possible to disclose this information due to taxpayer confidentially.

The table below contains the available aggregate figures in respect of these assets which have been claimed and the amount which was offset against taxable profit (data in respect of the latter is available from 2020 on only). I have been advised by Revenue that data for earlier years are not available for statistical analysis.

Year Claimed: €M Offset: €M
2022 147,054 67,054
2021 131,324 70,324
2020 94,237 40,237
2019 46,208 N/A
2018 45,365 N/A
2017 38,332 N/A
2016 35,737 N/A
2015 28,871 N/A

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