Written answers
Tuesday, 8 July 2025
Department of Finance
Tax Code
Séamus McGrath (Cork South-Central, Fianna Fail)
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328. To ask the Minister for Finance if he would amend the rules governing the residential zoned land tax to exclude the period where an active planning application or appeal is underway on a given site.; and if he will make a statement on the matter. [37286/25]
Paschal Donohoe (Dublin Central, Fine Gael)
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Finance Act 2021 introduced Part 22A Residential Zoned Land Tax (RZLT) into the Taxes Consolidation Act 1997. RZLT is designed to prompt residential development by owners of land that satisfies the relevant criteria for the tax, that being that the land is zoned for residential or mixed-use (including residential) purposes and that it is serviced.
RZLT is an annual tax, calculated at a rate of 3% of the market value of the land within its scope. The tax is due and payable from 2025 onwards in respect of land which satisfied the relevant criteria on 1 January 2022, or in the course of 2022, as where land satisfies the relevant criteria after 1 January 2022, RZLT will be first due in the third year after the year in which it satisfies the relevant criteria. RZLT first arose on 1 February 2025 and the 2025 liability was payable by 23 May 2025, subject to certain exceptions.
The objective of RZLT is to activate land for residential development. To this end, the legislation underpinning RZLT provides for the tax to be deferred in certain circumstances, including where planning permission is obtained and, within 12 months of the grant, works are commenced on the site.
Section 653AF of the Taxes Consolidation Act 1997 provides for a deferral of RZLT where a grant of planning permission in respect of land within the scope of the tax is the subject of an appeal by a party unconnected to the applicant or, if different, the owner of such land. In such circumstances, the development in respect of which permission has been granted cannot commence until such time as the appeal concludes; as such, RZLT arising in the course of the appeal is deferred until the relevant process is complete. If the appeal concludes with the grant of planning permission being upheld, the tax deferred in accordance with this provision is no longer due and payable. If the appeal results in the grant of planning permission being overturned, the tax deferred is payable, with interest.
As with all taxes, RZLT is kept under regular review by officials in my department and any changes will be considered as part of the annual finance bill cycle.
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