As the Deputy will be aware, the figures referred to by the Comptroller and Auditor General are extracted from a study carried out by the Revenue Commissioners in 2002 on the effective tax rates for high earning individuals based on the tax year 1999-2000. A similar study was undertaken in 1997.
One of the conclusions drawn from the 1997 study was that the use of capital allowances on the expenditure on buildings in tax designated areas and on hotels was one of the main methods of reducing the tax bills of high earners to very low levels. Subsequently, in the budget for 1998, I capped the amount of annual capital allowances on such buildings that could be off-set against non-rental income and, in the case of hotels throughout most of the country, I abolished in total the capital allowances against non-rental income.
As the Deputy will be aware, the 2002 study indicates an increase in the effective tax rate of high earners in 1999-2000 compared with earlier years. However, it is clear that some high earners continue to achieve substantial reductions in their tax liability as a result of certain tax reliefs. The study indicates that property based capital allowances continue to be the chief instrument used by high-income earners to reduce their taxable income by substantial amounts. It is also clear that the 1998 changes were not fully in effect by 1999-2000. Accordingly, in the budget for 2003, I abolished capital allowances for investment in registered holiday homes and reduced capital allowances for hotels to the rate applying generally to industrial buildings. I also indicated that a range of tax incentives would not be extended beyond their end-2004 termination date. All these measures will reduce the opportunities for very high earners to pay relatively low effective rates of tax.