Written answers

Tuesday, 15 October 2024

Photo of Jim O'CallaghanJim O'Callaghan (Dublin Bay South, Fianna Fail)
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205. To ask the Minister for Finance the estimated cost of a 0.5% reduction in the 0.5, 2%, 4%, 8% and 11% rates of USC post the enactment of measures announced in Budget 2025. [41490/24]

Photo of Jim O'CallaghanJim O'Callaghan (Dublin Bay South, Fianna Fail)
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206. To ask the Minister for Finance the estimated cost of a €1,000 increase in the income band of the 0.5, 2%, 4%, 8% and 11% rates of USC post the enactment of measures announced in Budget 2025. [41491/24]

Photo of Jim O'CallaghanJim O'Callaghan (Dublin Bay South, Fianna Fail)
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207. To ask the Minister for Finance the estimated cost of a €1,000 increase in the reduced rate of USC 0.5% and 2% bands post the enactment of measures announced in Budget 2025. [41492/24]

Photo of Jim O'CallaghanJim O'Callaghan (Dublin Bay South, Fianna Fail)
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208. To ask the Minister for Finance the estimated cost of a 0.5% reduction in the 0.5%, 2% band of the reduced rate of USC post the enactment of measures announced in Budget 2025. [41493/24]

Photo of Jim O'CallaghanJim O'Callaghan (Dublin Bay South, Fianna Fail)
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209. To ask the Minister for Finance the estimated cost to abolish the USC surcharge of 3% on non-PAYE income of more than €100,000 post the enactment of measures announced in Budget 2025. [41494/24]

Photo of Jim O'CallaghanJim O'Callaghan (Dublin Bay South, Fianna Fail)
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210. To ask the Minister for Finance the estimated cost of a €50 increase in the personal tax credit, employee PAYE, earned income, home carer tax, single person child carer, incapacitated child carer, blind person tax credits post the enactment of measures announced in Budget 2025, in tabular form. [41495/24]

Photo of Jim O'CallaghanJim O'Callaghan (Dublin Bay South, Fianna Fail)
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211. To ask the Minister for Finance the estimated cost of a €1,000, €2,500, €5,000, €10,000 and €15,000 increase in the single person and married one earner standard rate income tax bands post the enactment of measures announced in Budget 2025. [41496/24]

Photo of Jim O'CallaghanJim O'Callaghan (Dublin Bay South, Fianna Fail)
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212. To ask the Minister for Finance the estimated cost of a €1,000, €2,500, €5,000, €10,000 and €15,000 increase in the higher rate of income tax bands post the enactment of measures announced in Budget 2025. [41497/24]

Photo of Jack ChambersJack Chambers (Dublin West, Fianna Fail)
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I propose to take Questions Nos. 205 to 212, inclusive, together.

I am advised by Revenue that following the announcement of Budget 2025 on the 1st of October 2024, Revenue is in the process of updating their income tax estimates model to take account of these changes.

Once finalised, Revenue will publish a revised Ready Reckoner, which will set out the costs and/or yields associated with various potential changes to tax policy. This will be published by the 25th of October 2024 and will be available on the Revenue website at

www.revenue.ie/en/corporate/information-about-revenue/statistics/ready-reckoner/index.aspx.

Once published, Revenue will then be in a position to provide estimates for 2025 relating to changes to income tax policy, on a post-Budget 2025 basis.

Photo of Jim O'CallaghanJim O'Callaghan (Dublin Bay South, Fianna Fail)
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213. To ask the Minister for Finance the estimated cost of adjusting entrepreneur relief from a 'per venture' limit to a 'lifetime limit' post the enactment of measures announced in Budget 2025. [41498/24]

Photo of Jack ChambersJack Chambers (Dublin West, Fianna Fail)
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Revised Entrepreneur Relief is provided for in Section 597AA of the Taxes Consolidation Act 1997. It provides that a reduced rate of 10% of Capital Gains Tax (CGT) applies in respect of a chargeable gain or chargeable gains on a disposal or disposals of qualifying business assets by an individual up to a lifetime limit of €1 million. Any chargeable gain in excess of the €1 million lifetime limit is to be taxed at the standard rate of CGT (currently 33%).

As the relief currently applies up to a lifetime limit of €1 million, I understand the Deputy is asking the estimated cost of adjusting the relief from a ‘lifetime limit’ to a ‘per venture’ limit. I am advised by Revenue that, as the relevant tax returns do not include information regarding the overall portfolios of qualifying business assets held by entrepreneurs or their likely patterns of disposal, data is not available from which to estimate the likely cost of the change outlined by the Deputy.

Photo of Jim O'CallaghanJim O'Callaghan (Dublin Bay South, Fianna Fail)
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214. To ask the Minister for Finance the estimated cost to increase the maximum value of share options allowable under KEEP from 100% of a recipient's salary to 150% post the enactment of measures announced in Budget 2025. [41499/24]

Photo of Jack ChambersJack Chambers (Dublin West, Fianna Fail)
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Section 128F of the Taxes Consolidation Act (“TCA”) 1997 provides for the Key Employee Engagement Programme ("KEEP”), which came into effect on 1 January 2018. The aim of the incentive is to support SMEs in Ireland in competing with larger enterprises to recruit and retain key employees, by way of a targeted share option programme. Where the provisions of section 128F TCA 1997 are met, an exemption from income tax, USC and PRSI applies to a qualifying employee on any gain realised on the exercise of a qualifying share option.

In order to qualify for this beneficial tax treatment, there are a number of conditions to be satisfied in relation to the employee, the company and the share options. In order to be considered a ‘qualifying share option’ the share to be acquired must be ordinary fully paid up shares and the option must be held by the employee for a minimum period of 1 year from the date of grant. The option must also be exercised within 10 years of the grant of that option.

In addition, section 128F(1) provides for a restriction on the total market value of all shares in respect of which qualifying share options can be granted in the company to an employee or director. With effect from 1 January 2019, this value cannot exceed:

  1. €100,000 in any one year of assessment,
  2. €300,000 in all years of assessment, or
  3. 100% of the qualifying individual’s annual emoluments in the year of assessment in which the qualifying share option is granted.
Resultant from the conditions above, I am advised by Revenue that it is not possible to estimate the cost of increasing the cap in relation to the annual emoluments of the qualifying individual – (iii above). There are a number of reasons for this-
  • it is not possible to predict the uptake on the KEEP scheme – as noted above, the share option must be exercised within 10 years of the grant of the option, however there is no obligation on the employee to exercise such an option,
  • Revenue cannot predict future annual emoluments in respect of any individual,
  • it is not possible to foresee the number or value of shares that a ‘qualifying company’ may be willing to allocate under the KEEP scheme,
  • it is also impossible to ascertain whether a company or an individual will continue to be “qualifying” for the purposes of KEEP for any subsequent years of assessment, and
  • the restrictions imposed on the total market value of shares cannot be looked at in isolation for any particular year. For instance, in order to determine whether an option granted in 2022 is a ‘qualifying share option’ for the purposes of KEEP, it needs to meet all the relevant conditions including restrictions (i.e., i, ii and iii above). These restrictions refer not only to the year of assessment 2022, but also to any previous years of assessment since the inception of KEEP in 2018 or the first year in which the company operated the scheme. For instance, in order to determine whether an option is qualifying for 2022, any options granted since 2018, or the first year the scheme was operated by the company, will have to be considered to ascertain that the €300,000 threshold in respect of the total market value in all years of assessments is met.
I am advised by Revenue that the estimated cost of increasing the maximum value of share options allowable under KEEP from 100% to 150% of an individual’s salary is not available. However, a cost to the exchequer figure in respect of revenue foregone and employer PRSI exemption on KEEP, under the current conditions of the scheme is available. The cost to the exchequer of operating KEEP is €1.6m for 2022, which is the most recent year published in the annual Cost of Tax Expenditures table available at . This is a maximum cost, which is calculated with reference to the marginal rates of income tax (40%) and USC (8%), and employee PRSI at 4%.

In respect of the employer PRSI exemption that applied in respect of KEEP for the year 2022, this cost is estimated at €0.3m, calculated with reference to an employer PRSI rate of 11.05% for 2022. As the rate of employer PRSI depends on an employee’s weekly earnings, it is not possible to provide an exact figure. It is worth noting that the 11.05% rate of employer PRSI has increased to 11.15%, effective from 1 October 2024. The rate will further increase to 11.25%, effective from 1 October 2025.

As announced in my Budget day speech, a comprehensive review of the taxation of share based remuneration, incorporating the responses received to a public consultation, has been published and its recommendations will be considered in due course.

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