Written answers
Thursday, 28 May 2026
Department of Finance
Departmental Inquiries
Niall Collins (Limerick County, Fianna Fail)
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279. To ask the Minister for Finance if he intends to address an issue (details supplied) with the RZLT; and if he will make a statement on the matter. [41328/26]
Simon Harris (Wicklow, Fine Gael)
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The Residential Zoned Land Tax (RZLT) was introduced in Finance Act 2021 and first charged in 2025. It seeks to increase housing supply by encouraging the activation of residential development on lands which are suitably zoned and appropriately serviced.
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 is serviced.
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. Such a landowner is not required to pay the annual RZLT liability arising on 1 February by 23 May in each of the years to which the planning permission relates where certain conditions are met. The RZLT deferred in these circumstances will, on the making of a claim, not be payable where development is completed within the timeframe set out in the planning permission and a certificate of compliance on completion is in place to evidence same.
Tax deferred on foot of the grant of planning permission and the commencement of residential development within 12 months of that grant becomes due and payable in certain circumstances, including where a relevant site is subject to a change of ownership without the lodgement of certificates of compliance on completion in respect of all residential development as outlined in the planning permission, apart from where the transfer is between companies which are members of the same group and certain conditions are met. As such, should a developer have deferred RZLT following the commencement of residential development on a relevant site, and the site is later sold to a third party without the lodgement of certificates of compliance on completion in respect of all residential development as outlined in the planning permission, the RZLT deferred by the developer in such circumstances becomes due and payable.
This tax was developed in line with the principle that tax liabilities crystallise on sale. Before the sale of a relevant site is completed, the vendor is required to pay any unpaid RZLT due in respect of a liability date falling before the date of sale, including where deferred tax becomes due and payable as outlined above, and to submit any outstanding returns.
As with all taxes, RZLT is kept under regular review by officials in my department and any changes would be considered as part of the annual finance bill cycle.
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