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Dáil Éireann Debate, Tuesday - 21 May 2024

Tuesday, 21 May 2024

Questions (98)

Matt Carthy

Question:

98. Deputy Matt Carthy asked the Minister for Finance the number of non-domiciled individuals taxed on a remittance basis; the number of individuals who have self-assessed with Revenue as non-domiciled in each of the years 2021, 2022 and 2023; and if his Department is considering changes to the non-domicile regime to restrict the remittance basis of taxation that applies to the regime. [22782/24]

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Written answers

An individual who is resident or ordinarily resident, but not domiciled in the State, is taxable on the remittance basis of tax in respect of foreign income and gains. Such individuals pay tax on:

(1) Income and gains arising in Ireland,

(2) Foreign income which they “remit” or bring into the State, and

(3) Foreign gains which they "remit" into the State where the gain accrues from the disposal of assets situated outside the State.

It should be noted that the benefit of the remittance basis only arises where such an individual has foreign income or gains for the year. An individual who is taxable on the remittance basis in respect of foreign income or gains is required, under self-assessment provisions, to report the amount of the foreign income or gains which are remitted to the State in a tax return for the year in which the remittance occurs.

I am advised by the Revenue Commissioners that the latest number of self-assessment Form 11 income tax returns for 2021 in which a taxpayer has indicated that they are non-domiciled is 53,900. The data is on a taxpayer unit basis, where jointly assessed couples are counted as one unit, and the taxpayer unit is counted where either party to the joint assessment has indicated that they are not domiciled. Relevant statistics for 2022 and 2023 are not yet available. I am also informed by the Revenue Commissioners that an individual who is not domiciled in the State is not required to report whether they have availed of the remittance basis of foreign income and gains when completing a return. On this basis, it is not possible to confirm the numbers of taxpayers who avail of the remittance basis of tax in cases where they are in receipt of foreign income and gains.

As with all areas of taxation policy, the remittance basis of taxation will be considered as part of the annual budgetary and Finance Bill process.

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