Section 825B of the Taxes Consolidation Act 1997 (which had effect for the 2009 tax year onwards) provides relief to certain individuals who are not Irish domiciled and who, before they came to the State, had been living and working in a country with which the State has a double taxation agreement. This is sometimes referred to incorrectly as the Special Assignment Relief Programme. The provision applies where the individual is sent by his or her foreign employer to work in the State for that employer or for an associated company of that employer and continues to be paid from abroad. Under the provision, such individuals may have the tax on the income from the foreign employment that is attributable to duties of that employment exercised in the State reduced to the greater of the tax due on either (a) €100,000 plus 50% of the income of the employment over that amount; or (b) the income from that employment remitted to the State (any tax deducted by the employer via the PAYE system is deemed to be a remittance). Figures derived from information provided by taxpayers in income tax returns for the years 2009 to 2011 inclusive are as follows. It should be noted by the Deputy that these figures have been compiled in the time available and may not represent the final figures as work is still ongoing to analyse the relevant data. I am advised that the Revenue Commissioners will write separately to the Deputy if the figures are amended when the full data extraction had been completed.
|
Year
|
Numbers Availing
|
Estimated Cost to Exchequer
|
Average Cost
|
|
|
|
€
|
€
|
|
2011
|
15
|
456,020
|
30,400
|
|
2010
|
14
|
358,690
|
25,620
|
|
2009
|
5
|
78,320
|
15,660
|
Figures denoting money amounts have been rounded to the nearest 10.
Tax returns for 2012 are due to be filed October/November of 2013.
In relation to the new Special Assignee Relief Programme introduced in Section 14 of Finance Act 2012, as I indicated to the Deputy in my reply to his question of 9 May last, employer returns received to date indicate that there were 6 individuals who qualified for the relief with 2 of them receiving an aggregate total tax-free remuneration of €39,767. Job increases were reported as numbering 26 with 2 jobs also reported as retained because of the relief. It is expected that the 4 individuals who are not reported in the employer returns as receiving tax-free remuneration are expected to claim it when they submit Form 11 tax returns for 2012 in late 2013. It is also possible that not all employers have submitted a SARP return yet. Also, the figures provided do not include the details for claims that are not included in employer returns received to date but will be made in the Form 11 tax returns for 2012 to be filed under the self-assessment system in October/November of 2013.
