Tuesday, 11 Nov 2014

Written Answers Nos. 214-228

Pensions Reform

Questions (216)

Michael McGrath

Question:

216. Deputy Michael McGrath asked the Minister for Finance regarding the changes contained in section 63(1) of the Finance Bill which exempts administration services of defined contribution occupational pension schemes from VAT, except one member arrangements, if that clause was inserted in order to comply with the European Court of Justice ruling in the so-called ATP case; if he is aware that the vast majority of defined contribution one member schemes are administered by life companies whose pension business is VAT exempt anyway; his views on whether section 63(1) breaches the principle of fiscal neutrality by confirming a distortion in the marketplace between insured providers of one member schemes and uninsured providers, given that uninsured providers are, in the main, small Irish businesses rendering exactly the same services as those provided by insurers; if he will consider an amendment which would eliminate the words other than a one member arrangement, within the meaning of that Act, from the relevant subsection; and if he will make a statement on the matter. [43184/14]

Written answers

Minister for Finance

The proposal contained in Section 63(1) of the Finance Bill 2014, which exempts the management of defined contribution occupational pension schemes from VAT, is necessary to ensure Irish VAT law complies with the recent decision of the European Court of Justice in the ATP Pension Services (Case C-424/12).

The ECJ judgment, which has direct effect in the State, concerns the VAT treatment of management services provided to a defined contribution occupational pension scheme. The ECJ found that the pension funds at issue may be regarded as a special investment fund where the funds are invested using a risk spreading principle and the pension customers bear the investment risk. The Court also held that the essential characteristic of a special investment fund is the pooling of assets of several beneficiaries, enabling the risk borne by those beneficiaries to be spread over a range of securities.

I am advised by the Revenue Commissioners that it is their understanding that "one member arrangements" are generally administered by life insurance companies and through Small Self-Administered Schemes (SSAS's). The trustees of "non-insured" contribution pension schemes have a much greater discretion as to how the scheme funds are invested, and there is no requirement that the investments are pooled. In such circumstances, it is Revenue's view that the administration of such schemes do not meet the ECJ principles for VAT exemption. In contrast, many smaller schemes in Ireland are "insured" schemes in which investments are made on a unitised/non-segregated basis and concern a contract of insurance held by the pension holder. The trustee has little opportunity to determine the investment strategy in relation to the assets underlying the policy. The management of such schemes by an insurance company are exempt as the supply relates to insurance intermediation.

The principle of fiscal neutrality precludes economic operators carrying out the same transactions from being treated differently in relation to the levying of VAT. Revenue are of the view that the principle of fiscal neutrality is not breached as the providers are supplying different services to the pension holder.

Question No. 217 answered with Question No. 186.

Irish Water Funding

Questions (218)

Michael McGrath

Question:

218. Deputy Michael McGrath asked the Minister for Finance if he will provide in detail moneys transferred to date or committed to Irish Water as investments on behalf of the State; and if he will make a statement on the matter. [43205/14]

Written answers

Minister for Finance

In July 2013 Irish Water and the National Pensions Reserve Fund (NPRF) entered into a two year €250m bridging loan facility with Irish Water, which benefits from a State Guarantee. The NPRF Commission has recently agreed to an increase in the amount of this facility by €50m to €300m.

As part of Budget 2014, Government agreed that a €240 million equity investment would be made in Irish Water from the Exchequer. In accordance with this agreement, in July 2014 a capital contribution in an amount of €185 million was made and it is expected that a €54 million convertible debt instrument will be issued by Irish Water to the Minister for Finance shortly.      

Irish Water also receives funding from the Local Government Fund (LGF).  The amount made available under the LGF to the end of October 2014 is €424 million.  The funding being made available to Irish Water from the LGF in 2014 will fund water related expenditures incurred heretofore by local authorities; these expenditures were previously met by local authorities from their own resources and general purpose grants.  

Tax Reliefs Availability

Questions (219)

Lucinda Creighton

Question:

219. Deputy Lucinda Creighton asked the Minister for Finance the cost to the Exchequer of extending a 20% child care tax relief to all working families in the State for each child from six months up to the point where they enter the primary school system. [43232/14]

Written answers

Minister for Finance

It is not possible to provide an accurate cost to the Deputy of the provision of tax relief in respect of childcare costs for children of pre-primary school age as reliable figures are not available for the numbers of children in childcare, the costs incurred by their parents and the number of parents who are paying tax.

However, a tentative figure can be calculated by using the 2013 "Indecon Report on Support for Childcare for Working Families and Implications for Employment" and statistics provided by the Department of Social Protection in relation to children in receipt of child benefit.

The Indecon report concluded that the average cost of childcare per pre-school child per week was €133 or €6,916 per annum in 2013. According to DSP figures on the numbers and ages of children in receipt of child benefit in 2013, there were approximately 489,500 children under 6.

If tax relief at the standard rate of 20% were provided on the costs of childcare in respect of these children, it would result in a cost to the Exchequer of in the region of €680 million per annum. However, it must be borne in mind that these figures are extremely tentative and the real cost could be much higher. 

I have no plans to introduce such a tax relief as it could be seen to unfairly discriminate against those individuals who stay at home and look after their children. While wanting to encourage participation in the workforce, equally we cannot say to individuals who stay at home to mind children that they are making a less valuable contribution to society.

In addition, tax relief is only of benefit to those in the tax net and it is estimated that in 2014, 39% of income earners will be exempt from income tax. It could also be argued that any tax relief would most likely be absorbed by childcare providers in the form of higher prices.

Having said this, I would like to assure the Deputy that the Government acknowledges the continuing cost pressures on parents, particularly those with young children. In recognition of these cost pressures, a number of support measures are in place to ease the burden on working parents. These include the Community Childcare Subvention (CCS) programme, which funds community childcare services to enable them to charge reduced childcare fees to qualifying parents, the Childcare Education and Training Support (CETS) programme which provides free childcare places to qualifying Solas and VEC trainees and the Early Childhood Care and Education (ECCE) programme which provides for a free pre-school year for children in the year before commencing primary school. Generous entitlements to paid and unpaid maternity leave as well as child benefit payments are also provided.

The Department of Social Protection provides financial support to families on low pay by way of the Family Income Supplement (FIS) and additionally to one-parent families through the one-parent family payment.

Furthermore, a Single Person Child Carer tax credit of €1,650 is available as well as an additional standard rate band of €4,000. This credit and band is payable to any single person with a child under 18 years of age or over 18 years of age if in full time education or permanently incapacitated. The primary claimant may relinquish this credit and the increase in the rate band to a secondary claimant with whom the child resides for not less than 100 days in the year. To claim the Single Person Child Carer Credit a claimant must not be married, in a civil partnership or cohabiting.

In relation to exempting childcare costs from tax when the service is provided by an employer, a relief did exist in the form of a benefit-in-kind exemption. However, this relief was abolished in Finance Act 2011. The Commission on Taxation recommended its abolition, citing equity issues in relation to those parents whose employers did not provide such facilities.

As the Deputy will appreciate, I receive numerous requests for the introduction of new tax reliefs and the extension of existing ones.  In considering these, I must be mindful of the public finances and the many demands on the Exchequer given the current budgetary constraints.  Tax reliefs, no matter how worthwhile in themselves, reduce the tax base and make general reform of the tax system that much more difficult.

Irish Water Funding

Questions (220)

Pearse Doherty

Question:

220. Deputy Pearse Doherty asked the Minister for Finance with regard to correspondence (details supplied) the way in which the figure of €550 million is arrived at. [43284/14]

Written answers

Minister for Finance

The figure of €550m referred to by the Deputy represents the impact on the general government deficit for 2014 & 2015 if Irish Water is included within general government. This figure was provided to Deputy Liam Twomey on 9th October 2014 and was based on projections at that time and does not incorporate all of the measures announced in Budget 2015.

If Irish Water is included in general government, all expenditure incurred and revenue generated will be treated as general government expenditure and revenue respectively.

For 2014, in broad terms, Irish Water will incur expenditure in the region of €1.5 billion in respect of establishment costs, the metering programme, operational and capital expenditure. This would then be treated as general government expenditure. Circa €0.3 billion of revenues of Irish Water would also count as general government revenue, bringing the net impact on the general government deficit to circa €1.2 billion. However, a subvention to Irish Water of €0.45 billion is already treated as general government expenditure.  A further amount of €0.2 billion of capital expenditure undertaken by Irish Water is also being counted as general government expenditure because it was carried out in respect of assets not yet transferred from Local Authorities. Excluding these two items that are already charged to general government, the balance of €550m is the shortfall in Irish Water income compared to its expenditure and represents the impact on the deficit if Irish Water is included in general government.

For 2015, in broad terms, Irish Water will incur expenditure in the region of €1.5 billion. This would then be treated as general government expenditure. Circa €0.5 billion of revenues of Irish Water would also count as general government revenue. This includes €0.2 billion of commercial water charges and €0.3 billion in domestic water charges.  A subvention from the Local Government Fund of €0.45 billion is already included as general government expenditure. The balance of €550m is the shortfall in Irish Water income compared to its expenditure and represents the impact on the deficit if Irish Water is included in general government.

VAT Exemptions

Questions (221)

John McGuinness

Question:

221. Deputy John McGuinness asked the Minister for Finance if water chargs will be exempted from VAT. [43294/14]

Written answers

Minister for Finance

The supply of water by local authorities and Irish Water is exempt from VAT. This VAT exemption applies to all supplies of water, including supplies to domestic households, businesses and others. 

Banking Operations

Questions (222)

Thomas P. Broughan

Question:

222. Deputy Thomas P. Broughan asked the Minister for Finance if his Department or the Central Bank of Ireland investigated the actions of a bank in its promotion and sale of investments to customers (details supplied) in 2007 and 2008 which were allegedly mis-sold to some investors and resulted in significant losses for a number of investors. [43309/14]

Written answers

Minister for Finance

The Central Bank is the relevant authority for such a matter and has provided me with the following response.

There is insufficient information provided to give an informed response. However from the very limited reference to the product, we understand that the product was aimed at experienced investors seeking growth as the product invested in the stock market and investors also had the option of a geared version of the product. No issues have been brought to the Central Bank's attention regarding the sale of this fund. 

If a consumer is unsatisfied with the sale of this product to them, or the advice they received, they should consider making a formal complaint to the bank concerned or the entity which the product was purchased from. Further, if consumers (as defined under FSO legislation) are unsatisfied with the outcome of a complaint they may have the opportunity to register their complaint with the Financial Service Ombudsman for adjudication. If more information is brought to the attention of the Central Bank, then the subject can be examined further.

Financial Services Ombudsman

Questions (223)

Thomas P. Broughan

Question:

223. Deputy Thomas P. Broughan asked the Minister for Finance if he is satisfied that persons lodging complaints with the Financial Services Ombudsman who cannot afford third party or legal representation or do not want such representation are sufficiently supported in lodging complaints and being made aware of the necessary documentation and other particulars required to have complaints processed. [43311/14]

Written answers

Minister for Finance

Firstly, I must point out that the Financial Services Ombudsman is independent in the performance of his statutory functions. 

However, I have been informed by the Financial Services Ombudsman's Bureau (FSOB) that it acts in an impartial manner and when dealing with unresolved disputes between a consumer and a financial service provider the FSOB does not advise either party.

I have been further informed that the FSOB always offers to guide a Complainant through the complaint process and offers support (such as further explanation or referral to an appropriate body) if needed. A comprehensive website and detailed brochures are available to Complainants.  In addition, the FSOB informs me that it is more than willing to explain all stages of the process, what documentation is necessary and why it is necessary to progress the complaint.

The FSOB's staff members are experienced in assisting and informing the Complainants throughout the complaint process. If a Complainant is representing themselves (which occurs in most complaints) the FSOB provides information and guidance in an impartial manner to that Complainant. If a Complainant seeks assistance in compiling and drafting their complaint, he/she will be directed to seek independent advice and / or avail of information on the FSOB's website. Depending on the circumstances, the FSOB might direct a Complainant to do one or more of the following:-

- Visit  the website to understand how the FSOB handles complaints;

- Contact their local Citizens Information for advice on the best way to deal with financial problems and complaints;

- Contact the  Money Advice and  Budgeting Service for impartial information and guidance about  their money;

- Contact the Free Legal Aid Centre;

- Seek independent legal advice.

Therefore it appears to me that Complainants are sufficiently and appropriately supported throughout the complaints process.  

Financial Services Ombudsman Data

Questions (224)

Thomas P. Broughan

Question:

224. Deputy Thomas P. Broughan asked the Minister for Finance if he will provide in tabular form the number of complaints handled by the Financial Services Ombudsman in the years 2012, 2013 and to date in 2014; the number of these complaints in which oral hearings took place; and the number of such complaints in which the complainant was represented by a third party, including a member of the legal profession. [43312/14]

Written answers

Minister for Finance

At the outset, I must point out that the Financial Services Ombudsman is independent in the performance of his statutory functions.

However, the Financial Services Ombudsman has informed me that the information requested by the Deputy is as follows (I have assumed that the Deputy wishes to refer to complaints closed during the particular years):-

Total Complaints closed	Oral Hearings	Third Party Representation
2012 -  7,871	11	1,591
2013 - 8,641	31	1,753
2014 - 5,167* (to 7/11/2014)	27*	744*

 * These are initial unaudited figures.   

Mortgage Data

Questions (225)

Michael McGrath

Question:

225. Deputy Michael McGrath asked the Minister for Finance his Department's estimate, including a breakdown, of the number of residential mortgages here currently held by entities not regulated by the Central Bank of Ireland and which therefore do not have the statutory protection of the code of conduct on mortgage arrears; and if he will make a statement on the matter. [43317/14]

Written answers

Minister for Finance

The Deputy will be aware that the Central Bank's Code of Conduct on Mortgage Arrears (CCMA) is a statutory Code issued under Section 117 of the Central Bank Act 1989 and lenders are required to comply with the CCMA as a matter of law.  The CCMA applies to the mortgage lending activities of all regulated entities, with the exception of credit unions, operating in the State including:

- A financial services provider authorised, registered or licensed by the Central Bank of Ireland; and

- A financial services provider authorised, registered or licensed in another EU or EEA Member State and which has provided, or is providing, mortgage lending activities in the State.

I am aware of the concerns of some borrowers about sale of the mortgage books to funds that are not covered by the CCMA.  I have informed the House before that the details of the numbers of mortgages sold are considered commercially sensitive by the financial institutions involved. However, information from company announcements in the public domain, would suggest that between 8,000 and 10,000 mortgages in total have been sold to unregulated entities in recent years.

The Deputy will also be aware of the Government's intention to bring forward legislation to ensure that, where a regulated financial entity sells its loan book to an unregulated entity, the protections afforded under the Central Bank codes will continue to apply. The Government has reiterated this commitment on several occasions.

My Department ran a public consultation in July and August of this year seeking views on its proposed legislation to protect consumers whose loans are sold to unregulated entities. 19 submissions were received from a range of respondents from the financial services industry, consumer groups, public representatives and individuals and other stakeholders. These have been published on the Department's website at http://www.finance.gov.ie/what-we-do/banking-financial-services/consultations/responses-public-consultation-process-consumer.  Officials in my Department have carefully considered the submissions and are working with the Office of the Attorney General to progress this legislation. It is anticipated that it will be published by the end of this year

I have been informed by the Central Bank that it has communicated to lending firms its preference that the outcome of any sale of mortgage books by regulated entities would ensure continuity of borrower protections under the relevant Codes and also that the purchaser would have relevant policies and procedures, systems and control checks to appropriately manage a mortgage loan book. 

Mortgage Data

Questions (226)

Michael McGrath

Question:

226. Deputy Michael McGrath asked the Minister for Finance the number of residential mortgages here that are classified as sub-prime; the number of sub-prime lenders currently operating in the market; the total value of sub-prime mortgages outstanding; the rate of arrears on these mortgages; the actions specific to the sub-prime sector which are being taken to address arrears; and if he will make a statement on the matter. [43318/14]

Written answers

Minister for Finance

The Central Bank has advised that there is no such regulated category as 'sub-prime' lender but that phrase is sometimes used to refer to some non-deposit taking 'retail credit firms'. Retail credit firms are a regulated category of entities which are authorised to provide credit (in the form of cash loans) directly to individuals. Some firms authorised in this category are mortgage lenders. Retail credit firms have been subject to regulation by the Central Bank since 1 February 2008. A register of all Retail Credit Firms is available on the Central Bank website at the following link: http://registers.centralbank.ie/DownloadsPage.aspx.

I am informed by the Central Bank that, at end-June 2014, six of these firms had a total of 17,986 primary dwelling (PDH) mortgage accounts of which 5,047 were classified as restructured; four had a total of 772 buy to let (BTL) mortgage accounts of which 96 were classified as restructured.  Regarding the level of outstanding debt on these accounts, there was a total of €3.323bn in outstanding PDH debt and a further €0.171bn outstanding in BTL mortgage debt.  Of that outstanding debt, mortgage accounts amounting to €1.732bn (PDH) and €0.099bn (BTL) respectively were in arrears of over 90 days.  The Central Bank has advised that it does not publish the interest rates applied by regulated entities.

The Deputy will be aware that the Central Bank's Mortgage Arrears Resolution Targets (MART) announced in March 2013 set time bound and measurable targets for the 6 main banks requiring them to systematically address their arrears book.  The Central Bank has informed me that retail credit firms are not subject to the prudential standards set out in the Central Bank's MART. However, the same consumer protection framework applies to retail credit lenders as to other regulated lenders including the Consumer Protection Code and the Code of Conduct on Mortgage Arrears (CCMA). As such the Central Bank engages with these firms in relation to their treatment of borrowers under the mortgage arrears resolution process as provided for in the CCMA. In particular, the CCMA sets out requirements for all mortgage lenders, including retail credit firms, dealing with borrowers facing or in arrears on a mortgage secured on a primary home and provides a strong consumer protection framework to ensure that borrowers struggling to keep up mortgage repayments are treated in a fair and transparent manner by their lender and that long term resolution is sought by lenders with each of their co-operating borrowers in mortgage difficulty. 

The Central Bank has informed me that retail credit firms were also included in the scope of the Central Bank's review of the 'Implementation of the Revised CCMA' by mortgage lenders, the purpose of which was to ensure that mortgage lenders achieved full implementation of the requirements of the revised CCMA by end December 2013.

The Central Bank has advised that during 2012, retail credit firms reported that 59 properties were repossessed following a court order, accounting for 24% of total properties repossessed following court orders. During 2013, these lenders reported that 53 properties were repossessed following a court order, accounting for 15% of the total.  In Quarter 2 of 2014, retail credit firm lenders reported that 12 properties were repossessed following a court order, accounting for 11% of total properties repossessed following court orders.

The Central Bank continues to engage with all mortgage lenders, including retail credit firms, in relation to lenders' mortgage arrears resolution strategies and approaches to dealing with borrowers in or facing arrears.  Early and effective engagement between borrowers and lenders is key to resolving cases of mortgage difficulty.  Where there is effective and meaningful engagement regarding a mortgage difficulty, the data show that an increasing number of durable long term mortgage restructures is being put in place.

Mortgage Resolution Processes

Questions (227)

Michael McGrath

Question:

227. Deputy Michael McGrath asked the Minister for Finance the number of complaints that have been made against banks for non compliance with the code of conduct on mortgage arrears since it was instituted; the number that have been upheld; the sanctions that have been imposed on banks for cases of non-compliance; the maximum sanction that may be handed down; and if he will make a statement on the matter. [43319/14]

Written answers

Minister for Finance

The Central Bank's Code of Conduct on Mortgage Arrears (CCMA) is a statutory Code issued under Section 117 of the Central Bank Act 1989 and lenders are required to comply with the CCMA as a matter of law. The Central Bank has advised that it does not publish statistics in relation to the number of complaints against banks for non-compliance with the CCMA. However, it is planning to test compliance with the CCMA later this year. Part III C of the Central Bank Act 1942 provides the Central Bank with the power to administer sanctions in respect of the commission of prescribed contravention(s) by regulated financial service providers and the participation in the prescribed contravention(s) by persons concerned in their management. The Central Bank has informed me that where a concern arises that a prescribed contravention has been or is being committed, the Central Bank may investigate.  Following an investigation an inquiry may be held where there are reasonable grounds to suspect that a prescribed contravention has been or is being committed.  The inquiry shall decide if the prescribed contravention has occurred and determine the appropriate sanctions. 

A prescribed contravention could be a breach of:

- a provision in legislation

- a code, or a direction, given pursuant to legislation

- a condition or requirement imposed on a regulated financial service provider

- any obligation imposed on a regulated financial service provider by the Central Bank

Following an inquiry, the Central Bank, for example, can impose one or more of the sanctions below:

- caution or reprimand;

- direction to refund or withhold all or part of money charged or paid, or to be charged or paid, for the provision of financial service by a financial service provider;

- a direction to pay the Central Bank a monetary penalty (not exceeding the greater of €10,000,000 or 10% of turnover where the financial service provider is a body corporate or an unincorporated body and not exceeding €1,000,000 where the financial service provider is a natural person and for persons concerned in the management of a financial service provider);

- disqualification of a person from being concerned in the management of a regulated financial service provider;

- revocation or suspension of an authorisation;

- direction to the regulated financial service provider to cease committing the contravention;

- direction to pay the Central Bank all or part of its costs incurred by the Central Bank in the investigation of the matter and the holding an inquiry. 

The Central Bank has advised that to date, it has not imposed a sanction on a mortgage lender in relation to breaches of the CCMA.  More information on the Administrative Sanctions procedure can be found at the following link: http://www.centralbank.ie/regulation/processes/EnfI/Pages/Introduction.aspx). 

The Deputy will be aware that the Central Bank monitors compliance with the statutory consumer protection requirements through its on-going engagement with firms, reviews and research, themed inspections, mystery shopping, and advertising monitoring.  The Central Bank regularly conducts themed inspections to ensure compliance with all of its codes of conducts, including the CCMA. Themed inspections examine issues across a sector. Where a specific compliance issue arises with an individual firm, this is addressed directly with the firm and where appropriate, regulatory action may be taken.  Breaches of regulatory requirements are dealt with in accordance with the Administrative Sanctions procedure. To promote compliance, the Central Bank provides feedback on themed inspections and publish the main issues on its website.  The Central Bank has conducted a number of themed inspections on the CCMA since its introduction in 2009.  Details of these themes and the feedback issued can be found at the following link: http://www.centralbank.ie/regulation/processes/consumer-protection-code/compliance-monitoring/Pages/themed-inspection.aspx .

The Central Bank's plan for themed inspections in 2014 (http://www.centralbank.ie/press-area/press-releases/Pages/CentralBankPublishesProgrammeofThemedReviews.aspx ) includes an inspection of mortgage lenders to test compliance with the revised CCMA.  Compliance with the CCMA is also a Central Bank enforcement priority for 2014.

Where a borrower believes that their lender has not complied with or in any way disregarded the CCMA, he/she may make a complaint to their lender. The lender must seek to resolve the borrower's complaint in line with the complaints handling process set out in provisions 10.7 to 10.12 of the Central Bank's Consumer Protection Code.  Each lender must also establish an Appeals Board to consider and determine any such appeals submitted by borrowers.  If the borrower remains dissatisfied following the outcome from the complaints or appeals process, he/she may then refer the matter to the Financial Services Ombudsman (FSO) who deals independently with unresolved complaints from consumers about their individual dealings with all regulated financial service providers. 

I have been informed by the Office of the Financial Services Ombudsman (FSO) that in relation to Mortgage Arrears Resolution Process (MARP) complaints, where issues of sustainability/repayment capacity are in dispute, the FSO is only in a position to investigate a complaint as to whether the provider, in handling a mortgage arrears issue, correctly adhered to its obligations pursuant to the CCMA.

Details of the number of findings where the issue of CCMA/MARP was raised and the findings issued are detailed below:

Reporting Period	Finding Issued	Upheld	Partly Upheld	Not Upheld
2012	11	0	5	6
2013	69	1	14	54
2014 [to 30.10.14]	88	2	19	67

These statistics relate to complaints made/referred to the FSO only and do not include complaints in relation to non-compliance which may have been made directly to the Central Bank of Ireland and which may have been dealt with by the CBI.  

Office of Public Works Properties

Questions (228)

Pat Rabbitte

Question:

228. Deputy Pat Rabbitte asked the Minister for Public Expenditure and Reform if the Office of Public Works is in a position to provide the number of famine victims buried at Kilmainham, Dublin 8; and if he will make a statement on the matter. [42953/14]

Written answers

Minister of State at the Department of Public Expenditure and Reform

There are 63 recorded deaths in Kilmainham Gaol in the relevant Famine period. It is not clear however that any of these deaths are directly attributable to famine causes and cannot therefore be definitively described as such. While the figure would seem low compared to the number of deaths throughout the country at the time, it possibly reflects that, bad though the conditions were in the Gaol in the 1840s, they still offered subsistence levels of food and shelter which at least kept inmates alive while the population outside the Gaol was sustaining much higher mortality rates.

The Office of Public Works (OPW) has no information in relation to interrals within the Gaol in this period, though there are, clearly, graves on the Kilmainham site which have arisen because of the various executions that took place there. We cannot therefore with any assurance of complete historical accuracy ascribe any of the deaths at the Gaol during this period exclusively to the Great Famine.