Dáil Éireann díospóireacht -
Tuesday, 25 Nov 2003

Vol. 575 No. 3

Written Answers. - Tax Code.

Joan Burton

Ceist:

158 Ms Burton asked the Minister for Finance the amount of tax credit provided by way of double taxation relief, for the United Kingdom, the USA, Spain and other jurisdictions; and the number of taxpayers availing of such credits in respect of each category. [28354/03]

Minister for Finance (Mr. McCreevy)

I am informed by the Revenue Commissioners that the details of claims for double taxation relief are not captured in such a way as to provide a basis for identifying the amounts relating to different countries. This information either could not be obtained or could not be obtained without conducting an extensive investigation of the Revenue Commissioners' records.

However, aggregate data are available in regard to claims for double taxation relief against the liability to corporation tax and income tax of corporate and individual taxpayers respectively in respect of the year 2000/01. This information is as follows:

	Numbers	Double taxation relief allowed€m
Corporate	444	281.5
Individuals	4,725	20.2

Joan Burton

Ceist:

159 Ms Burton asked the Minister for Finance the number of taxpayers in the Revenue 2002 study of the top 400 taxpayers who availed of tax relief in respect of car parks; the highest relief for an individual taxpayer; and the average relief. [28355/03]

Minister for Finance (Mr. McCreevy)

While the Revenue report referred to by the Deputy was carried out in 2002, I should point out that it related to data for the income tax year 1999-2000.

I am informed by the Revenue Commissioners that a total of nine partnerships involved in multi-storey car parks were examined as part of the top 400 study and that these partnerships generated aggregate losses of €9,725,723. Approximately 90 individuals were involved in these nine partnerships. The average loss relief claimed per individual was in the region of €100,000. These losses would have been allowed at the individuals' marginal income tax rates. The top rate was 46% in 1999-2000.

Revenue has advised me that in the time available it has not been possible to identify the highest individual amount of multi-storey car park relief claimed. This would have required Revenue to go back and examine all of the files involved. However, the highest amount of loss relief claimed by any one of the nine partnerships concerned was €2,576,719.

It should be noted that the Revenue Commissioners conducted a similar study in 1997 on the effective tax rate of high earners in the tax years 1993-94 and 1994-95. One of the conclusions drawn from the 1997 study was that the use of capital allowances was one of the main methods of reducing the tax bills of high earners to very low levels. I subsequently introduced provisions in the 1998 Finance Act which placed a cap of €31,750 per annum on the amount of capital allowances a taxpayer could claim on investments outside his or her own business.

In the case of the 2002 study by the Revenue Commissioners, it was noted that some individuals were still able to avail in 1999-2000 of the pre-1998 budget legislative provisions because of the normal transitional measures associated with the budget changes. The impact of these transitional measures has been declining in the intervening years and will eventually cease.