I propose to take Questions Nos. 134 and 135 together.
I am advised by Revenue that Table 1 includes a breakdown by tax heading of debt that was subject to Appeal before the Tax Appeals Commission at 31 January 2019 while Table 2 includes a breakdown by tax heading of debt that was subject to Insolvency Proceedings (Liquidations, Receiverships and Examinerships) at the same date.
Where tax liabilities are subject to either the Appeals or Insolvency processes, Revenue is legally prevented from using its debt collection or enforcement sanctions to secure collection. In insolvency situations, Revenue can also be legally obliged to accept reduced payments in accordance with creditor status rules.
Revenue has also clarified that the number of actual taxpayer cases involved in Appeals and Insolvency proceedings at 31 January 2019 was 1,688 and 2,006 respectively, which is less than the cumulative figures quoted in the provided tables. The tables reflect higher numbers because Appeal or Insolvency cases can include more than one tax heading.
Table 1: Debt Under Appeal at 31 January 2019 by Tax Heading
Tax
|
Appeal Numbers by Tax Heading
|
Amount (€m)
|
Capital Gains Tax
|
121
|
€117
|
Corporation Tax*
|
120
|
€2,505
|
VAT
|
193
|
€198
|
Income Tax
|
1,261
|
€338
|
PAYE
|
98
|
€29
|
PRSI
|
92
|
€4
|
USC
|
53
|
€2
|
Other
|
43
|
€43
|
|
Total
|
€3,236
|
*It may be of note to the Deputy that 5 corporation tax appeals were received in the last week of December 2018 that amounted to approximately €2.1 billion.
Table 2: Insolvency Debt at 31 January 2019 by Tax Heading
Tax
|
Insolvency Numbers by Tax Heading
|
Amount (€m)
|
Corporation Tax
|
278
|
€15.4
|
VAT
|
674
|
€32.2
|
Income Tax
|
17
|
€1.2
|
PAYE
|
889
|
€37.5
|
PRSI
|
1,078
|
€21.2
|
USC
|
598
|
€2.3
|
Relevant Contracts Tax
|
191
|
€3.4
|
Other
|
46
|
€0.3
|
|
Total
|
€113.5
|