I am informed by the Revenue Commissioners that there is nothing in Irish tax law that makes reference to the term "tax exile" status. I am assuming in referring to "tax exiles" the Deputy is thinking of Irish citizens or Irish domiciled individuals claiming to be non-resident for tax purposes and who are living abroad primarily for tax reasons. For the 2009 tax year, the latest year for which statistics are available, 8,493 non-resident individuals filed Irish tax returns in respect of their Irish source income or income derived from working here. However, many of these non-residents are foreign nationals or have a foreign domicile; and many of the non-resident Irish citizens or Irish domiciled individuals included in this figure may have become non-resident for reasons unrelated to taxation, but have retained Irish investments such as rental property. Such individuals could not be categorised as "tax exiles" under any reasonable definition of that term.
The taxation of individuals in the State is broadly in line with that prevailing in most other OECD jurisdictions, that is to say —
(a) Individuals who are resident in the State for tax purposes (based on the number of days of presence in the State) are taxable here on their worldwide income; and
(b) Individuals who are not resident here for tax purposes pay tax here only on income arising in the State and on income derived from working here.
In addition, in general non-resident individuals are also liable to Irish Capital Gains Tax on disposals of land, buildings in the State, or shares deriving their value from these assets and certain or other assets such as minerals in the State or other assets related to exploitation of such assets. They are not liable to Irish Capital Gains Tax on assets outside of this category, for example, share or equities in companies not deriving their value from land, buildings in the State, etc. There are variations on this position if the non-resident individual is ordinarily resident and/or domiciled in Ireland.
The Domicile Levy was introduced in Finance Act 2010 and is charged on an individual:
who in any year is Irish domiciled and an Irish citizen,
whose worldwide income in the year exceeds €1m,
whose Irish located property in the year is greater than €5m, and
whose liability to Irish income tax for the year is less than €200,000.
The levy will apply to both resident and non-resident individuals who meet the above criteria. The levy will be charged for 2010 and subsequent years, but the payment for each year can be made at any time up to 31 October in the year following the valuation date, which is 31 December of each year. The first valuation date was 31 December 2010 and the tax return and payment of the levy for 2010 is not due until 31 October 2011.
As with other areas of taxation, these rules are constantly kept under review. The level and timeframe of any taxation changes in this area will be determined in the context of Budgets over the lifetime of the Government.