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Dáil Éireann debate -
Wednesday, 5 Jul 2017

Vol. 957 No. 1

Priority Questions

Help-To-Buy Scheme

Michael McGrath

Question:

17. Deputy Michael McGrath asked the Minister for Finance the status of the independent impact analysis of the help-to-buy scheme; when he plans to clarify the future of the scheme; and if he will make a statement on the matter. [31610/17]

This question relates to the help-to-buy scheme. As we know, an independent impact analysis which Fianna Fail insisted on is under way. I would like the Minister to clarify when he intends to make a decision on the future of the scheme. There has been considerable speculation by Ministers and others that the scheme may be scrapped, which is causing a lot of uncertainty in the market. I look forward to hearing the Minister's comments.

As the Deputy will be aware, during the Committee Stage debate on the Finance Bill 2016 my predecessor agreed to commission an independent impact assessment of the effects of the help-to-buy scheme incentive for completion prior to budget 2018. Following a competitive tender process, Indecon Economic Consultants was appointed in April to undertake the assessment. The purpose of the project is to assess whether the policy objectives on the supply of new homes are being met, the impact, if any, the scheme is having on new and second-hand house prices and on the residential property market generally. The report is being conducted on an independent basis. Indecon has devised a methodological approach which involves the use of data from the Revenue Commissioners and other sources, conducting interviews with key stakeholders and undertaking a full analysis of the policies surrounding the scheme. In direct answer to the Deputy's question, the report is scheduled to be completed by the end of August. Once received, its contents and findings will be considered and I will decide on any appropriate action or actions to take in the context of my deliberations as part of the annual budgetary process.

The Government remains of the view that the help-to-buy incentive has the potential to increase the supply of new build homes, which is a crucial factor in addressing the problems facing the housing market generally. In that regard, it should be noted that a number of indicators point to a strengthening recovery in the housing market. For example, the latest Ulster Bank construction purchasing manager's index rose to a 15-month high in May and the index suggests housing activity has continued to expand every month since July 2013.

I reassure members of the public who may be in the process of applying for the help-to-buy incentive, or those who have applications pending, that speculation concerning its abolition will not impact negatively on their applications. I will signal well in advance any proposed change to the incentive following my consideration of the Indecon report.

The speculation is within the Government - by the Taoiseach; the Minister, Deputy Eoghan Murphy, and anonymous sources within the Government - with strong hints that the help-to-buy scheme may well not survive for very much longer. The Minister knows what our position is. The impact analysis should have been made in advance of the scheme being introduced. As it was not, we insisted on it being done immediately and it is now due to be completed by the end of August, as the Minister said. However, the position is that the speculation triggered by comments made by members of the Government has caused a huge amount of uncertainty in the property market. We have a situation where prospective first-time buyers are inevitably going to rush into the market at a time when there is a very small stock of new housing units available. This will inevitably lead to a spike in the prices of the very small number of new homes available. I want to know when the Minister is going to clarify the position to bring an end to the uncertainty. If he does have the report at the end of August, will he wait until budget time in mid-October to make an announcement, even if it is very clear from the independent report that the help-to-buy scheme is, in fact, pushing up prices?

I have outlined the Government's stance on the matter which has been reiterated by other Ministers who have commented publicly on it recently. The process is as I have outlined. If changes are due to be made to the scheme, I will signal them well in advance understanding the effect my words about the scheme might have on those who are considering using it or may already have applied. To aid the House in its consideration of the scheme, the Revenue Commissioners have shared figures with me regarding the performance of the scheme to date. It may be of interest to the Deputy and others that, in terms of the property values against which applications under the scheme have been made, just under 80% of the applications have been in respect of purchases of properties less than €375,000 and that approximately 60% of applicants have a loan-to-value ratio in excess of 85%. Therefore, there are people accessing the scheme for whom it is of help. I will be using the process I have outlined to the House and will signal well in advance changes due to be made.

The Minister has now used the phrase "well in advance" on three separate occasions. What I interpret from his comments is that he is preparing the ground for the abolition of the help-to-buy scheme, but he will give notice to prospective buyers and the market of that course of action. This matters to people. There are first-time buyers who are wondering whether they should try to buy now and definitely avail of the scheme, or if they should wait until next year when they will have saved more money in order that they will have to borrow less in order to enter the property market and buy their first home. This impacts on real people and the life-changing decisions they have to make; it is important, therefore, to bring clarity to the situation. The speculation and uncertainty were directly caused by the Government's intervention in the first place and then by the comments made in which very strong hints were given. It has been widely written about by independent commentators, for example, Davy, all of whom are making the point that it seems that the scheme is about to be brought to an end.

For one who is concerned about the effects comments could have on the housing market, the Deputy's own suggestion that the uncertainty about the scheme has been increased by me in outlining a process for which his own party looked and to which the Government agreed is not consistent. I have outlined the process which is to evaluate-----

It should have been done first.

I have outlined how it is to work and been very clear that I understand the value of the scheme. I have shared with the Deputy figures that show the help it offers to people who are looking to purchase a home. The Government's position on the matter is very clear. What I am doing is outlining a process that the Deputy sought, indicating how I will use it and recognising that the Government's position on the matter is clear and that the report generated by this process will be used to inform future policy making.

I remind Deputies of the need to try to stick to the time allowed as we ran two minutes over time on that question.

Universal Social Charge

Pearse Doherty

Question:

18. Deputy Pearse Doherty asked the Minister for Finance his plans with regard to the universal social charge in view of the conflicting positions of the programme for Government and the Taoiseach; and if he will make a statement on the matter. [31769/17]

The manifesto on which the Taoiseach won the internal Fine Gael election included a promise that, "Rather than abolishing the Universal Social Charge (USC) outright, we will merge the USC and PRSI into a new single Social Insurance payment". The programme for Government states something different: "To make Ireland’s personal taxation system more competitive, we will ask the Oireachtas to continue to phase out the USC as part of a wider medium-term income tax reform plan". The Fine Gael manifesto states, "Completing the abolition of the USC over a 5-year period as part of a wider reform of the tax system that keeps the tax base broad and limits the benefits for the highest earners". There are clearly three contradictory positions. Will the Minister outline to the House which of them is his position?

I am sure the Deputy will agree with me that our current system of personal taxation, including as it does three separate charges on income, through income tax, USC and PRSI, each with different income bases, reliefs and manners of assessment, is overly complex. It can be difficult for individuals to understand the personal tax system has the potential to lead to an increase in employment or, indeed, increases in the level of work undertaken by individuals.

The programme for Government commitment to the phasing out of the USC was specified as part of a wider medium-term process of income tax reform, which would maintain the breadth of the tax base, while reducing excessive tax rates for middle income earners and limiting the benefits for high earners.

We have made steady progress in reducing the personal tax burden in the three most recent budgets, with a particular focus on low to middle income-earners, and these reductions have been achieved primarily through cuts to the lowest three rates of USC. The top marginal rate of tax on income up to €70,044 has been reduced to 49%, and it must be remembered that, as recently as December 2014, the marginal rate of tax for a single individual on all income over €32,800 was 52%.

My long-term view of the USC is to see its integration into the existing PRSI code. My focus on reducing the income tax burden for those on low and middle incomes should be the guiding principle. This must be achieved in a way that is both affordable and sustainable. In this regard, the end result is more important than the means of achieving this outcome. At this point in the process, I have an open mind as to the elements of the income tax system that could be employed as policy levers, to achieve the ultimate aim of the programme for Government with regard to reducing the tax burden faced by low and middle income earners.

I call Deputy Doherty to ask a supplementary question.

As is the case in advance of all budgets, I have asked my officials to prepare papers examining a range of policy options for the short and medium term, and I will consider these in detail in advance of budget 2018.

I welcome the fact the penny seems to be finally dropping in Government Buildings and the parliamentary party meetings of Fine Gael, and of Fianna Fáil as it made a very similar promise as it wanted to abolish 90% of the USC. Fine Gael wanted to go the full hog and abolish 100%, which would erode more than €4 billion of our tax base. By 2021, with no policy changes, this tax would bring in €5.2 billion per year. At least now we seem to be hearing that a substantial portion of it, if not all of it, will be retained but will be renamed or remodelled into the PRSI. Something that is not very clear is the Minister said the Department will carry out another assessment. An assessment was done last year on how the Government could abolish the USC over a period of time. Will the Minister state categorically the USC tax base, on which the State depended on until now, will not be eroded in the way presented by the Government and by Fine Gael, which showed abolishing the USC would cost the State up to €4 billion?

I will not take any lectures from Sinn Féin on economic competence or economic policy-making. At present, we see the State in a position where it is able to invest back in public services, such as the 975 additional special needs assistants the Minister, Deputy Bruton, will confirm this afternoon, precisely because of a change in our economic circumstances that Sinn Féin said would never happen. Deputy Doherty has no right to lecture. Well, he has the right actually. Of course he has the right.

Of course I do, and I appreciate the Minister pointing it out.

I recognise he has the right, but he certainly does not have the track record to comment on the merits of economic policy options being considered by the Government. As I outlined already, I am very clear on what the long-term endpoint will be for the USC. We have a new Minister for Finance and a new Taoiseach. We are entitled to make our assessments of the landing points for important policy areas such as this. We believe the landing point is where we integrate the PRSI code into the USC code-----

A final supplementary question.

-----and in the meantime we will look to reduce the cumulative tax burden for employees and citizens in a way consistent with the programme for Government.

The Minister stands there and says I have no track record or the right because of my track record to make these points. Let me be clear, there was a discussion earlier on the help-to-buy scheme. It needs to be abolished, and in my view it will be abolished, because it is a reckless policy which the Government introduced.

Fianna Fáil and Deputy Michael McGrath sat on their hands and allowed it to be introduced at a time when we knew what would happen. I said at a meeting of the finance committee it would partly result in double-digit increases in house prices. All the people out there worth their salt are pointing out it was a reckless decision.

Excuse me, Chair, this is a follow-up question and I have my time.

I am telling you to put a question.

With regard to this policy, the Minister entered into a populist position in the general election arguing a €4 billion tax base could be eroded. Fianna Fáil had a similar position. It has now been pointed out to the Minister, not only by Sinn Féin but by the European Commission, the IMF, the ESRI and many other external bodies, that it is reckless. What is the current position of the Minister for Finance? Is it the position in the Government manifesto? Is it the position of the Taoiseach? Will the Government continue to use the reduced fiscal space available to erode the tax base? It did this last year, taking almost €400 million out of the tax net.

Now the Commission is telling us the Government may have underestimated the amount last year's cut could have cost.

I remind Deputy Doherty he asked a question when his time was up, one minute after he began to speak. The Minister has one minute to respond.

The Deputy is just disappointed I actually answered his question. To find Sinn Féin coming in here and accusing any other party of taking populist positions on their policy choices is beyond the pot calling the kettle black.

Abolishing the USC.

The Deputy's party has consistently stood up here and said all could be achieved without the need to make changes in economic policy.

Wrong. We said not to abolish the USC.

The Deputy's party has consistently stood up here over many years, as has Deputy Doherty, and said that the change in circumstances in our country would not happen, that the changes made in economic policy to get our country to this point would not be successful, and that we would not see a return to employment. This has happened. I have outlined to the Deputy my view and the Taoiseach's view on the long-term role of the universal social charge. It should be at the heart of a new social contract between our citizens, through how we integrate it into the PRSI code. The views regarding how we make our tax code more competitive and how work is rewarded of course will be handled in a way consistent with the programme for Government and consistent with the supply and confidence agreement we have with Fianna Fáil.

Insurance Compensation Fund

Michael McGrath

Question:

19. Deputy Michael McGrath asked the Minister for Finance his plans to ensure that all outstanding claims associated with the collapse of a company (details supplied) in 2014 are met in full through the Insurance Compensation Fund, the proceeds from the liquidation process and a contribution from the industry if necessary; and if he will make a statement on the matter. [31611/17]

I am like a broken record on the issue of Setanta Insurance, but this is because there is a deep injustice here affecting almost 1,600 claimants who, more than three years since the collapse of Setanta Insurance, still do not know whether they will get 100% of their claims met either through the Insurance Compensation Fund, the proceeds from the liquidation or a contribution from the insurance industry. They need and deserve clarity and I hope the Minister of State, Deputy D'Arcy, can provide it today.

The Supreme Court delivered its judgment on 25 May 2017 and overturned the previous decisions of the High Court and the Court of Appeal that the Motor Insurers' Bureau of Ireland is liable in respect of third party motor insurance claims made against the policyholders of Setanta Insurance. The consequence of this is that the Insurance Compensation Fund, ICF, has been deemed responsible for the payment of such third party claims.

As the judgment has been delivered, it is now possible to begin the process of making payments in accordance with the provisions of the Insurance Act 1964, as amended. Payments can only be made from the ICF with the approval of the High Court, and only if it appears to the High Court that it is unlikely that the claim can be met otherwise than from the ICF. If satisfied, the High Court can order payments out of the ICF up to 65%, or €825,000, whichever is the lesser, due to relevant third party claimants.

The liquidator has confirmed to the Department that, as of 20 June 2017, the number of open claims is 1,578. The Office of the Accountant of the Courts of Justice and the State Claims Agency are working with the liquidator to progress the making of payments to these claimants.

In this regard, there are currently 324 claims ready for settlement and which have been validated by the State Claims Agency. The process for bringing these claims to the High Court for approval has commenced but a date has yet to be agreed.

Over and above the 65% ICF, insurance compensation fund, payment, it is expected that a proportion of the balance of money due to third party claimants will be met from the proceeds of the distribution of Setanta’s assets on completion of the liquidation process. However, it is not possible to say definitively at this stage what proportion of the claims this will amount to. Current indications are that this is unlikely to be sufficient to cover the entire 35% gap, however.

I thank the Minister of State for his reply. The system has failed the people in question. Of course, the company itself failed the people and has principle responsibility. The system of regulation and also the State failed them. Those involved have had their lives put on hold due to accidents, some of which happened well before the liquidation of Setanta in 2014. Some involve serious injuries and the Minister of State knows of one particular case in which fatalities were involved. There are court awards of which not one cent has yet been paid. This is fundamentally unfair.

We need to hear something new from the Minister of State. I have not even heard him or the Government say that it is their objective that these people will get 100% of their claims met. We know 65% of claims will be met from the ICF, while the liquidation process will deliver some surplus, perhaps meeting up to 30% of claims. Will the Minister of State meet with the insurance industry to agree a way of ensuring the claimants involved will get 100% of their claims met?

As I said, 324 cases have been concluded. The legislation is clear that within six months they will receive 65% of their payment from the ICF. The issue is the shortfall following this ICF payment. We do not know what amount will be gathered from the liquidation process.

The State simply cannot intervene at this stage. We are awaiting an up-to-date actuarial process on the information involved. The information we are operating on at the moment dates back to 2014. When we get the actuarial information, we will see exactly how much of the 35% shortfall it may involve. The State is not committing to or against anything. We will review it and see what the shortfall will be. However, we do not know what it is and we cannot commit to an open-ended shortfall at this moment.

The picture is not open-ended because the process of new claims has closed and there is a figure in terms of the overall potential liability. We know the ICF will pick up 65% of the bill. Will the Minister of State ask the insurance industry if it has any proposals to resolve the situation and also seek an update from the liquidation process?

The Minister of State spoke about the Towers Watson actuarial report which goes back to 2014. We were told that up to 30% of the outstanding claims may be met. If 65% comes from the ICF and up to 30% from the liquidation process, then the shortfall will be modest. It will be a stain on the industry if these people do not get 100% of their claims met. I want to hear from the Minister of State today that it is the Government's objective to work with all the stakeholders involved, namely the liquidator, the insurance compensation fund and the industry, to ensure the people caught up in this mess will not ultimately be out of pocket as a result.

I will give a commitment that I will work with everybody to achieve the best possible result. However, the information we have is clear. If the Government attempts to step into the conversation at this stage, potentially the liquidator could reduce the amounts it will make available to claimants. The Government would then subsequently have to pick up a further amount. I would not like that to happen.

We will see what the amount is when the new actuarial process has concluded. We have given a commitment that we will review the matter and do the best we can for those caught up in this. There are over 1,500 cases. Of these, 324 will move quickly over the next couple of months. That is the start of the process. The Government could not do anything until the Supreme Court case was over. It is now over and we are keeping matters under review.

National Debt Servicing

Danny Healy-Rae

Question:

20. Deputy Danny Healy-Rae asked the Minister for Finance if he will renegotiate the amount of debt Ireland has to repay with a view to reducing it; if he will seek an extension of the time period in which the debt must be repaid in view of the fact that it is unfair to ask this generation to shoulder the burden; and if he will make a statement on the matter. [31625/17]

Will the Minister renegotiate the amount of debt Ireland has to repay with a view to reducing it? Will he seek an extension of the time period in which the debt must be repaid in view of the fact that it is unfair to ask this generation to shoulder the burden? All sections of our community are suffering because of this debt.

I presume the Deputy is referring to EU-IMF programme-related debt when he asks about renegotiation. This debt accounts for about one quarter of Ireland’s total debt.

My Department, in conjunction with the National Treasury Management Agency, NTMA, is constantly looking to avail of any appropriate opportunity for savings on the cost of our EU-IMF programme loans and the matter is constantly reviewed. Our debt-to-national income ratio has declined significantly in recent years. However, I recognise the limitations of using GDP, gross domestic product, as a proxy for our national income. For a more meaningful assessment of trends in public debt in Ireland, it is important to look beyond this simple measure.

While other debt sustainability measures such as the debt-to-revenue ratio and the interest-to-revenue ratio are also improving, they clearly demonstrate that our debt level is high by international standards. Accordingly, reducing it must remain a priority. Our economy is growing strongly. Our public finance deficit is declining, as are our debt service costs. We are now running a primary budget surplus. All of this is positive from a debt sustainability perspective. In addition, the proceeds from the recent sale of part of the Government’s shareholding in AIB will reduce the overall level of public debt.

As regards seeking renegotiation as suggested by the Deputy, he should be aware that significant improvements to the terms of our EU-IMF programme loans have already been secured since they were initially agreed in late 2010. There have been two separate maturity extensions granted to loans from the EFSM, European financial stabilisation mechanism, and the EFSF, European financial stability facility. These extensions mean that the next EFSF maturity is not until 2029, while it is not expected that Ireland will have to refinance any of its EFSM loans before 2027. All of this has delivered significant savings for this and future generations.

I thank the Minister for his reply.

Last year, Greece paid €8 billion to service debts of €350 billion, while Ireland paid €7.5 billion to service debts of €214 billion. Why did it cost us almost as much as Greece to service €100 billion less?

Middle-income earners cannot continue paying 51% or 52% tax. Services have been cut, including those for people with disabilities. Even death grants are not to be had anymore. The European Central Bank lent the money at 0.5% and then started off demanding 5% and 5.5% interest to get the money back. Irish people have paid for 42% of the European banking crisis. Average banking debt across the EU is €192 per person. In Ireland, it is €9,000 per person. The next highest country is Germany at €491 and then Latvia at €317.

Greece is still in a bailout programme. It is involved in reducing spending on public services and investment, as well as changing public pensions.

We have all that behind us. We have made those changes. We are out of a bailout programme and we are now in a position in which we are able to fund our own debt on a day-to-day basis. We are seeking to pay back money we secured in a bailout programme.

The Deputy asked me what changes were made to make our debt more sustainable. We made changes in regard to the interest rates in terms of how we accessed funding from the European Union and other countries. Those savings were worth over €9 billion over the original seven and a half years of the loans. We made decisions to extend the maturities or the length of time over which we would pay back debt to European institutions. This removed the need for the State to refinance nearly €20 billion worth of debt between 2015 and 2022. We made a decision to repay over four fifths of our IMF loans, which will deliver interest savings of over €1.5 billion. We are securing the kind of change the Deputy is seeking. The difference between Ireland and Greece is as I have tried to outline to him.

Ireland is a small country with a small population. We do not have oil wells or gold mines. It is the working people who are paying this debt. It was not the working people or the people of Ireland who caused the problem; it was the bondholders and the bankers.

I ask the Minister to tell the ECB bankers that we will pay. Irish people have always paid their way. We cannot pay until we have the money, however, and there is too much pressure on the current generation given what they are suffering at present. Germany should understand this well because it did not finish paying its First World War debt until three or four years ago. We still need to do better and the Government, including the Minister, needs to do better in this regard. The economic recovery has not gone far beyond the Red Cow.

It is precisely because of the scale of debt we have that the Government has made the decision, as we are gaining money back from our banking system through the sale of a quarter of AIB, for example, to put the money back into reducing our national debt. Being in a position where our national debt grows in an unsustainable way is a threat not only to future generations but also to the current one.

On the Deputy's question regarding the time over which we are paying back our debt, the proportion of our debt that is maturing for longer than five years is approximately 30%. The proportion in Belgium is 40%, the proportion in France is 50%, and that in Italy is also 50%. Therefore, we are seeking to pay back our debt over a longer period. Balancing our books is the most significant day-to-day contribution we can make to stabilise the debt and continue to reduce it.

Tax Avoidance

Seamus Healy

Question:

21. Deputy Seamus Healy asked the Minister for Finance his plans to legislate before the summer recess to make certain that a tax-avoidance loophole cannot continue in view of the report in a newspaper (details supplied). [31794/17]

Since 2011, up to 200 high net worth individuals, in other words wealthy and powerful people in society, including many household names, have been involved in a tax scam allowing them to avoid paying up to €500 million in tax. This involves the transfer of valuable rights attaching to shares in a company to shares owned by its members. I ask the Minister to put a stop to this once and for all by bringing in legislation before the recess to make sure this scam cannot continue.

I assume the Deputy is referring to a recent Circuit Court decision regarding the tax treatment of the transfer of share rights from a company to its shareholders. I am advised by the Revenue Commissioners that section 130(3)(a) of the Taxes Consolidation Act 1997 provides that the transfer of an asset by a company to its members constitutes a distribution for tax purposes. In regard to the case in question, the view of the Revenue Commissioners is that the transfer of rights attaching to shares owned by a company to shares owned by its members amounts to a transfer of an asset and, as such, is a distribution pursuant to section 130(3)(a).

Both the appeal commissioner and the Circuit Court have ruled in favour of the Revenue Commissioners and determined that the transfer of share rights is chargeable to income tax as a distribution in the way I have outlined. It is, therefore, considered by the Revenue Commissioners that the current legislation operates as intended and is sufficiently robust to provide for distribution treatment on such share rights transfers. The Revenue Commissioners will continue to challenge taxpayers who attempt to extract cash from companies in a tax-free manner.

The Revenue Commissioners carry out a robust programme of compliance interventions to minimise the burden on the compliant taxpayer and tackle the non-compliant taxpayer. This involves taking account of all risks that apply to a taxpayer across all taxes and duties. The role of the Revenue Commissioners is to recover any unpaid tax or duty along with interest and penalties.

The anti-avoidance units of the Revenue Commissioners specifically deal with the identification and challenging of aggressive tax-avoidance schemes in the way I have outlined.

I am simply not happy with the Minister's reply. My question relates to the future. We understand that this matter has been before the courts. The Circuit Court has found in favour of the Revenue Commissioners but we are aware that there is an appeal pending. We obviously cannot interfere with what happens in the courts but what happens in the future is not a matter for the courts; it is a matter for the Government. It is the responsibility of the Government to introduce legislation to ensure this loophole is closed, and closed for all time. I asked the Minister to do that again.

It is important to remember that the individuals involved are household names. They are very wealthy and powerful and are part of a group with significant financial assets, amounting to €37 billion more than at peak-boom levels. They have done very well out of the recession and the recovery. There is no doubt they have used their position in this regard effectively to be part of a scam against the State and the public generally.

The answer to the question is contained in the Deputy's own statement. Look at what happened. The Revenue Commissioners became aware of a matter and issued amended tax assessments in regard to it. A challenge was brought to the appeals commissioner and the Revenue Commissioners won. They were then brought to the Circuit Court, where they also won. There was a further appeal. That appeal was heard and the Revenue Commissioners won. Therefore, at each stage of this process when the Revenue Commissioners became aware of this issue and took action thereon, on which action it has been challenged, the law they have used and the way in which they have acted have been upheld. For those reasons, the Revenue Commissioners have advised me that no change to the law is needed as its position is being upheld. As the Deputy will be aware, in the Finance Acts 2012, 2013, 2014 and 2015, action was taken on the advice of the Revenue Commissioners and others to deal with the issue of tax avoidance.

Again, what I am referring to is the future. It is a matter for the Government to ensure that the activity in question is precluded in the future. The Minister referred to budgets in 2012, 2013 and 2014. Issues arose in those budgets since the profits of banks are now not taxable until 2047. The question of the taxing of vulture funds was addressed in those budgets. This matter needs to be tackled urgently. It needs to be dealt with through legislation and this should be done before the recess.

This matter is being tackled and dealt with by the Revenue Commissioners.

There would be a plausible case to make that the law needs to be changed if the Revenue Commissioners were losing the appeals or losing their case in the Circuit Court, but they are not. The law and the way the Revenue Commissioners are acting are being upheld by the recent rulings in the way that I have described to the Deputy. Since 2014, a number of taxpayers have settled their cases with the Revenue Commissioners in the particular area that Deputy Healy referred to. The yield to the Revenue Commissioners from those cases in tax, interest and penalties was €11.8 million. If at any point I am advised by the Revenue Commissioner on this or on any other matter that further legislation or a change in legislation is needed, of course I will consider it and bring it to the Oireachtas at the first possible opportunity. As the Deputy acknowledged himself in his question to me, the stance of the Revenue Commissioners has actually been upheld by each of the hearings the Deputy referred to.

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