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Tuesday, 11 Jun 2013

Written Answers Nos. 147-167

Universal Social Charge Application

Ceisteanna (147)

Robert Dowds

Ceist:

147. Deputy Robert Dowds asked the Minister for Finance if he has given further consideration to increasing the universal social charge levied on earnings of more than €100,000 for employees since this was raised with him last year; and if he will make a statement on the matter. [27120/13]

Amharc ar fhreagra

Freagraí scríofa

As the Deputy is aware, the Programme for Government states that as part of our fiscal strategy, the Government will maintain the current rates of income tax together with bands and credits and we will not increase the top marginal rates of taxes on income.

It is also a longstanding practice of the Minister for Finance not to comment, in advance of the Budget, on any tax matters that might be the subject of Budget decisions.

Banking Operations

Ceisteanna (148)

Andrew Doyle

Ceist:

148. Deputy Andrew Doyle asked the Minister for Finance if there are any banks in which the Government is a shareholder that are considering providing an ATM machine in the village of Rathvilly, County Carlow; and if he will make a statement on the matter. [27128/13]

Amharc ar fhreagra

Freagraí scríofa

I must point out to the Deputy that the Banks’ policies in relation to operational issues are a matter for the management and boards of the institutions. The Minister for Finance has no role in the day-to-day commercial and operational decisions of the banks, which includes this matter. These decisions are taken by the boards and management of the relevant institutions. Notwithstanding the fact that the State is a shareholder in the institutions, the Minister must ensure that the banks are run on a commercial, cost effective and independent basis to ensure the value of the banks as assets to the State, as per the Memorandum on Economic and Financial Policies agreed with the EU Commission, the ECB and the IMF.

Relationship Framework agreements have been specified that define the nature of the relationship between the Minister for Finance and the banks. This Frameworks were published on 30 March 2012 and can be found at: http://banking.finance.gov.ie/presentations-and-latest-documents/.

Question No. 149 answered with Question No. 134.

Banking Licence Breaches

Ceisteanna (150)

Clare Daly

Ceist:

150. Deputy Clare Daly asked the Minister for Finance the implications of the fact that AIB has an insufficient licence as referenced by the case of a person (details supplied). [27217/13]

Amharc ar fhreagra

Freagraí scríofa

I have been informed by the bank that due to data protection rules and customer confidentiality AIB is not in a position to discuss details of individual customer circumstances. Additionally AIB is unable to comment on this matter as there is on-going litigation in relation to the person concerned.

Tax Code

Ceisteanna (151)

Robert Dowds

Ceist:

151. Deputy Robert Dowds asked the Minister for Finance his plans to implement the OECD/IMF/World Bank recommendation that OECD countries conduct individual spill-over analysis of their tax policy to ensure that it is not adversely affecting developing countries; and if he will give a reassurance that tax policy here is not being exploited to the detriment of developing countries. [27228/13]

Amharc ar fhreagra

Freagraí scríofa

I assume the Deputy is referring to “Supporting the Development of More Effective Tax Systems”, a report to the G-20 Development Working Group by the IMF, OECD and the World Bank which was published in 2011.

As the report was prepared for a G-20 Working Group, the recommendations are, as would be expected, only addressed to G-20 member countries. The report, on page 27, considers that "it would be appropriate for G-20 countries to undertake a 'spillover analysis' of any proposed changes to their tax systems that may have a significant impact on the fiscal circumstances of developing countries". Although the recommendation is only addressed to G-20 countries, in any event there have been no changes to the Irish tax system since the report was published, that would have adversely impacted on developing countries. Indeed, one recent measure that has been designed to positively impact on developing countries has been the extension of the foreign earnings deduction to selected African countries in Budget 2013.

As a general point, the expansion of the tax treaty network is a key element of Irish tax policy. In negotiating double taxation treaties, the Revenue Commissioners aim to reach a convergence of positions that will ensure that the treaty is effective and efficient, meets the interests of each side as far as possible, is acceptable in both countries and works well in practice. The report notes the important role of double taxation treaties to serve the interests of both treaty partners.

Property Taxation Data

Ceisteanna (152)

Jonathan O'Brien

Ceist:

152. Deputy Jonathan O'Brien asked the Minister for Finance the number of households that have registered their compliance for payment of the property tax by the extended deadline, which ended at 8 p.m. on Wednesday, 29 May 2013. [27246/13]

Amharc ar fhreagra

Freagraí scríofa

I am advised by the Revenue Commissioners that, as they announced publicly on the night, by 8pm on Wednesday 29th May, 1,539,822 Local Property Tax Returns had been filed.

I am further advised that the number is now in excess of 1.55 million.

Ministerial Correspondence

Ceisteanna (153)

Andrew Doyle

Ceist:

153. Deputy Andrew Doyle asked the Minister for Finance if he will furnish members of the Oireachtas with a copy of the letter that is to be sent from him, through Ireland's Ambassador in Washington, to the Chairman of the United States Senate Subcommittee on Permanent Investigations, the United States Senator from Michigan, Carl Levin, rebutting his remarks that Ireland is a tax haven; and if he will make a statement on the matter. [27256/13]

Amharc ar fhreagra

Freagraí scríofa

I would like to advise the Deputy that this letter was published on the Department’s website on the 31st May 2013 and can be viewed at the following link: http://www.finance.gov.ie/documents/pressreleases/2013/mn226.pdf.

Banking Sector Investigations

Ceisteanna (154)

Pearse Doherty

Ceist:

154. Deputy Pearse Doherty asked the Minister for Finance the office holders and former office holders who have access to or had access to the Ernst and Young report on Irish Nationwide as discussed in the RTE documentary Inside Irish Nationwide. [27327/13]

Amharc ar fhreagra

Freagraí scríofa

Both I and the last Minister for Finance have had access to an Ernst & Young report concerning Irish Nationwide Building Society that was furnished to the Department of Finance.

However, I have been advised that given the on-going nature of the investigations by the Authorities, including in particular the investigation being conducted under the Central Bank’s Administrative Sanctions Procedure into historic lending practices at INBS, as well as internal considerations within the bank, the report cannot legally be published at this time. Publication of the report may be considered when the Central Bank proceedings are concluded or when any Garda investigation has been finalised (or any proceedings arising from such investigation concluded).

I have been informed by the Central Bank that the investigation into Irish Nationwide is on-going. Until the investigation has concluded, no decisions may be made as regards any future potential action.

Tax Yield

Ceisteanna (155)

Patrick Nulty

Ceist:

155. Deputy Patrick Nulty asked the Minister for Finance further to Parliamentary Question No. 52 of 2 May 2013, if he will provide, in tabular form, the total amount of revenue raised in each of the VRT categories for the aforementioned years; and if he will make a statement on the matter. [27328/13]

Amharc ar fhreagra

Freagraí scríofa

I am informed by the Revenue Commissioners that the net receipts in each VRT category (new and used) in respect of the years 2009, 2010, 2011 and 2012 are as follows:

New

2009

2010

2011

2012

Cars

A1

16,373,166

66,604,753

88,854,953

119,390,303

A2

76,322,051

108,562,065

133,854,115

107,053,328

A3

53,138,901

47,502,223

27,202,265

20,220,250

A4

38,220,314

31,518,427

18,474,002

13,000,405

A5

28,911,030

16,916,079

11,022,671

9,546,576

A6

15,603,672

9,295,367

8,606,705

9,187,720

A7

5,826,393

6,481,364

4,705,419

1,104,780

Cat B - Car Derived Vans

2,694,107

2,283,993

3,444,872

6,833,348

Cat C - Commercial Vehs

617,550

713,513

1,609,405

2,610,143

Cat M - Motorcycles

1,273,160

912,019

749,055

645,310

Total

238,980,344

290,789,803

298,523,461

289,592,163

Used

2009

2010

2011

2012

Cars

A1

3,093,608

5,918,644

9,339,385

11,289,045

A2

24,556,996

22,717,951

27,598,305

32,913,929

A3

41,197,776

27,683,401

25,687,500

22,913,638

A4

25,720,073

14,427,506

11,844,292

8,868,979

A5

17,351,800

8,428,912

5,593,867

4,800,477

A6

10,585,284

5,946,563

3,820,044

3,723,100

A7

8,611,877

5,009,664

3,039,494

2,218,970

Cat B - Car Derived Vans

2,998,088

1,090,668

1,088,015

1,220,808

Cat C - Commercial Vehs

1,030,100

672,617

1,292,500

1,430,200

Cat M - Motorcycles

1,276,956

799,458

526,883

374,512

Total

136,422,558

92,695,384

89,830,285

89,753,658

Excise Duties Yield

Ceisteanna (156)

Patrick Nulty

Ceist:

156. Deputy Patrick Nulty asked the Minister for Finance if he will provide, in tabular form, the total amount of revenue raised by the State in the years 2009, 2010, 2011 and 2012 from excise duties on a packet of 20 cigarettes and rolling tobacco; if he will also indicate the gross national tobacco related excise for each year; if he will provide the rate of excise that corresponds to the revenue information already provided; and if he will make a statement on the matter. [27330/13]

Amharc ar fhreagra

Freagraí scríofa

I am informed by the Revenue Commissioners that the available figures of excise receipts and rates in each Tobacco Products Tax category in respect of the years 2009, 2010, 2011 and 2012 are as follows:

-

Cigarettes

Fine Cut

Cigars

Other Smoking

Total

€m

€m

€m

€m

€m

2009

1,155.40

46.6

9.6

4.9

1216.5

2010

1,100.90

44.5

9.6

4.6

1159.6

2011

1,056.80

56.2

9.2

4

1126.1

2012

989.6

71

7.8

3.9

1072.3

Tobacco Products Tax Rates

With Effect from

15/10/2008

08/04/2009

07/12/2011

01/05/2012

06/12/2012

CIGARETTES

-

-

-

-

-

Specific duty per 1,000 cigarettes

€175.30

€183.42

€192.44

€233.11

€237.69

Ad Valorem duty as percent of retail price

18.28%

18.25%

18.03%

9.04%

8.83%

CIGARS (per kilogram)

€250.73

€261.07

€271.34

€271.34

€275.34

FINE CUT TOBACCO (per kilogram)

€211.58

€220.30

€228.97

€228.97

€248.61

OTHER SMOKING TOBACCO (per kilog)

€173.95

€181.12

€188.24

€188.24

€191.02

Vehicle Registration Issues

Ceisteanna (157)

Andrew Doyle

Ceist:

157. Deputy Andrew Doyle asked the Minister for Finance when approval will be given for remission of the vehicle registration tax in view of the fact that some organisations are waiting more than three months for applications to be approved; and if he will make a statement on the matter. [26791/13]

Amharc ar fhreagra

Freagraí scríofa

I am advised by the Revenue Commissioners that Section 134(3) of the Finance Act 1992 (as amended) and Statutory Instrument No. 353 of 1994 (Disabled Drivers and Disabled Passengers (Tax Concessions) Regulations, 1994 (as amended) provide for permanent relief from the payment of specified maximum amounts of VAT and VRT for persons registered under the scheme. This scheme is administered by the Revenue Commissioners, who have sole responsibility for the determination of claims for this relief.

The Revenue Commissioners have advised that all applications received are normally processed within a two-week period provided that all the necessary information and documentation is included. Recently a few cases were delayed whilst clarification of a certain legislative issue was being sought. This matter has been resolved and the Revenue Commissioners have advised that they have no applications to hand that have been received more than three months ago.

Tax Exemptions

Ceisteanna (158)

Anthony Lawlor

Ceist:

158. Deputy Anthony Lawlor asked the Minister for Finance if he will provide details of the number of religious organisations that are entitled to tax exemptions nationwide; and if he will make a statement on the matter. [26863/13]

Amharc ar fhreagra

Freagraí scríofa

Current tax legislation contains a range of tax exemptions and reliefs applicable to charitable organisations, which would include religious organisations. These exemptions and reliefs apply, for example, in relation to income tax and corporation tax on trading income and investment income and to capital acquisitions tax, capital gains tax and stamp duty. There are, in addition, a number of VAT exempt activities in which charitable organisations could engage, such as the provision of education or hospital care.

As these exemptions and reliefs apply to all qualifying charitable organisations rather than specifically to religious organisations Revenue does not generally maintain statistical data in respect of the entitlement of religious organisations to, or the use by them of, the various exemptions. However, a body applying to the Revenue Commissioners for charitable tax exemption under section 207 of the Taxes Consolidation Act 1997 (relating to rental and investment income) is required, as part of the application process, to indicate under which of the following charitable purposes the application is being made:

- Relief of Poverty;

- Advancement of Education;

- Advancement of Religion;

- Other works of a charitable nature beneficial to the community.

Of the bodies which are currently listed as being exempt, a total of 1,160 cite religion as their main or principal object. In that regard, however, some religious organisations would have been granted the exemption in respect of other main activities, for example, relief of poverty or advancement of education, and would be categorised under those headings rather than under religion. Accordingly, this figure does not necessarily fully reflect the number of religious organisations which are exempt under section 207. The Commissioners publish a list of all bodies which have been granted exemption under section 207 which can be accessed on the Revenue website at www.revenue.ie.

Tax Exemptions

Ceisteanna (159)

Anthony Lawlor

Ceist:

159. Deputy Anthony Lawlor asked the Minister for Finance his plans to review the tax exemptions to religious organisations, taking into consideration the country's current economic difficulties; and if he will make a statement on the matter. [26864/13]

Amharc ar fhreagra

Freagraí scríofa

Tax relief for charitable donations is provided for in section 848A of the Taxes Consolidation Act 1997. In order to qualify for this relief a charitable trust must be for either:

- The relief of poverty;

- The advancement of religion;

- The advancement of education; or

- Other purposes beneficial to the community.

In addition, the charity must have been authorised by the Revenue Commissioners as an eligible charity and hold charitable exempt status for at least two years.

Religious organisations in the State hold charitable tax exemption under the category of "advancement of religion". Parishes within a diocese are covered by the tax exemption granted to that diocese and, therefore, are eligible to submit claims for a refund of tax under the scheme. Relevant bodies of other religious organisations would also qualify for charitable tax exemption.

Bodies granted charitable tax exemption are subject to periodic risk-focused review by the Revenue Commissioners towards ensuring that the terms of the exemption continue to be fulfilled. Claims submitted by charitable bodies for a refund of tax are examined by the Revenue Commissioners to ensure that the applicants and the donations meet with the terms and conditions of the Donations Scheme.

As the Deputy will be aware, following a public consultation on proposed changes to the scheme of tax relief for donations to approved bodies, I announced changes to the scheme in the recent Budget. Full details can be found in Annex E of the Budget book. I have no plans to review the scheme further at this time.

Strategic Investment Bank Establishment

Ceisteanna (160)

Catherine Murphy

Ceist:

160. Deputy Catherine Murphy asked the Minister for Finance if he plans to establish a Government-backed strategic development bank similar to the KfW in Germany and the Spanish Instituto de Crédito Oficial in order to avail of any planned low-interest bilateral lending which may be forthcoming from such institutions in the near future; if he will confirm the process by which such loans could be drawn on by the State in the event that such bilateral loans are made available; and if he will make a statement on the matter. [26867/13]

Amharc ar fhreagra

Freagraí scríofa

I am aware from media reports that the German Government is in the process of finalising details of a bilateral arrangement with Spain that will enable KfW, the German state-owned development bank, to lend €800 million to the Instituto de Crédito Oficial (ICO), its Spanish counterpart, to provide liquidity and capital for Spanish SMEs. I understand that the idea is that the Spanish State will guarantee the loan and will supervise loan disbursement and supervision through the banking system. While this is a very interesting concept, any guarantee by the State in respect of borrowings by SMEs would need to be carefully considered. However, Deputies can rest assured that my Department is closely monitoring developments.

The Irish Government is very conscious of the need to encourage a vibrant and well-resourced SME sector. As part of the redeployment of the National Pensions Reserve Fund (NPRF) towards commercial investment in Ireland, the NPRF Commission announced on 9 January 2013 its commitment to a suite of three long-term funds to provide equity, credit and restructuring investment to SME and mid-sized corporates. The NPRF has completed commitments of €125 million to the SME Equity Fund, €50 million to the SME Turnaround Fund and €175 million - €325 million (depending on the amount of third-party investment raised) to the SME Credit Fund. As Deputies will be aware, the Government is preparing legislation to establish the Ireland Strategic Investment Fund (ISIF), through which resources from the NPRF will be channelled towards productive investment on commercial terms in the Irish economy. The ISIF will seek to leverage and maximise its resources by attracting private sector co-investment.

Excise Duties Yield

Ceisteanna (161, 164)

Stephen Donnelly

Ceist:

161. Deputy Stephen S. Donnelly asked the Minister for Finance the revenue raised on alcohol products for each month of 2013 to date since the introduction of increased excise duty on such products in last December's budget; and if he will make a statement on the matter. [26869/13]

Amharc ar fhreagra

Stephen Donnelly

Ceist:

164. Deputy Stephen S. Donnelly asked the Minister for Finance the revenue raised from taxes on alcohol products for each month of 2012; if he will provide in tabular form a breakdown of that revenue per type of alcohol product, spirits, beer, wine, other fermented beverages, and intermediate; and if he will make a statement on the matter. [26877/13]

Amharc ar fhreagra

Freagraí scríofa

I propose to take Questions Nos. 161 and 164 together.

The information requested by the Deputy is laid out in the tables below.

2012

Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

Sept

Oct

Nov

Dec

Total

Beer

32.3

13.8

19.4

25.9

23.5

30.3

27.9

23.5

26.1

25

27.5

32.8

308

Spirits

32.1

9.5

14.2

18.3

17.7

20.4

19

19.2

18.8

19.4

28.8

46.5

263.9

Wine

19.9

10.5

14.5

17

17.3

17.8

18.2

18

19.9

18.2

24.9

35.3

231.5

Cider

3.51

1.75

2.55

3.53

2.87

4.96

3.28

3.96

3.98

3.26

3.77

5.34

42.76

Total

87.81

35.55

50.65

64.73

61.37

73.46

68.38

64.66

68.78

65.86

87.97

119.94

846.16

2013

Jan

Feb

Mar

Apr

May

Total

Beer

33.1

14.5

20.1

31.2

25.1

124

Spirits

31.4

9.4

12.5

20.9

16.4

90.6

Wine

25.5

14.9

15.8

22.6

21

99.8

Cider

3.5

1.9

2.6

3.6

3.2

14.8

Total

93.5

40.7

51

78.3

65.7

329.2

* Intermediate products are included within each product category where appropriate.

Property Taxation Administration

Ceisteanna (162)

Brendan Smith

Ceist:

162. Deputy Brendan Smith asked the Minister for Finance if he will clarify matters in relation to the property tax; the estimate for a full year of this tax and if estimates are available for each county; the estimate for the full county of Dublin, including the four local authorities; if the proceeds from property tax will go into general Exchequer; when the power for a local authority to increase the tax will commence; and if he will make a statement on the matter. [26846/13]

Amharc ar fhreagra

Freagraí scríofa

I am informed by the Revenue Commissioners that Local Property Tax (LPT) Returns, personalised letters and an LPT Guide issued earlier this year to owners of 1.69 million residential properties either by post or by way of their ROS (Revenue Online Service) inbox.

The Commissioners have confirmed that at the end of the extended deadline 1,539,822 LPT Returns have been filed. I am further informed that this number is now in excess of 1.55 million.

As the Deputy will appreciate, the Commissioners' focus is on processing the Returns, dealing with correspondence, telephone calls and payment processing. It is therefore not possible at this time to provide the details requested by the Deputy until the Revenue Commissioners have had time to carry out the necessary analysis of the returns filed and payments.

For completeness sake, the Deputy should note that in light of the arrangements provided for local authorities and social housing associations in the Finance (Local Property Tax) (Amendment) Act 2013, discussions are taking place on the most practical approach to securing LPT returns from those bodies. Where local authorities and social housing associations are liable for LPT, payment is not due until on or before 1 January 2014.

I can confirm that the proceeds of the LPT will go into the Central Fund. Section 157 of the Finance (Local Property Tax) Act 2012 provides that, commencing in 2014, the Minister for Finance shall pay into the Local Government Fund an amount equivalent to the LPT, including any interest paid thereon, paid into the Central Fund during that year. The Minister for the Environment, Community and Local Government has recently confirmed that the Government has accepted, in principle, a policy position that from next year 80% of all Local Property Tax (LPT) receipts should be retained within the local authority areas where the properties are based.

From 1 January 2015 local authorities will have discretion to vary the rate by 15% above or below the national central rate. The national central rate of LPT is 0.18% for properties valued up to €1 million with the liability calculated based on the mid-point of the appropriate band. The national central rates for properties valued over €1 million are 0.18% on the first €1 million and 0.25% on the excess value over €1 million with no banding applied. The Government has committed not to amend the national central rates for the lifetime of this Government.

Question No. 163 answered with Question No. 138.
Question No. 164 answered with Question No. 161.

Fuel Rebate Scheme

Ceisteanna (165)

Regina Doherty

Ceist:

165. Deputy Regina Doherty asked the Minister for Finance if he will give consideration to the introduction of a recognised debit or credit card by transport operators to facilitate the operation of fuel excise rebate claims; and if he will make a statement on the matter. [26880/13]

Amharc ar fhreagra

Freagraí scríofa

Provision was made in this year’s Finance Act for the repayment to qualifying road transport operators of part of the mineral oil tax paid on the auto-diesel purchased by them for use in the course of business. This will apply to purchases made on or after 1st July 2013.

I am informed by the Revenue Commissioners, who have responsibility for the operation of the repayment scheme, that in order to qualify for the repayment, Revenue Commissioners’ Regulations will require that the auto-diesel be purchased in the State by the road transport operator, either in bulk or by means of a fuel card approved for that purpose.

It is not proposed to require the use of a specific fuel card, but a fuel card will only be approved where the fuel card provider will supply the information required by Revenue about purchases of auto-diesel made by means of the fuel card by a road transport operator. Revenue is currently arranging with fuel card providers for approval of fuel cards and the supplying of that information.

Exchequer Returns

Ceisteanna (166)

Joe McHugh

Ceist:

166. Deputy Joe McHugh asked the Minister for Finance the amounts of value added tax returns and PRSI returns that were lost due to liquidations in the years 2008, 2009, 2010, 2011, 2012 and to date in 2013. [26856/13]

Amharc ar fhreagra

Freagraí scríofa

I am advised by Revenue that it does not maintain returns data in a format that allows specific extraction for liquidation cases. Such data would require manual extraction on a case by case basis and would be very resource intensive.

Revenue does however maintain very precise data on all VAT and PRSI money that is written out as uncollectible arising from liquidations. The figures for the years requested by the Deputy are detailed in the table below.

-

VAT (€m)

PRSI (€m)

2008

37.90

17.89

2009

62.90

31.38

2010

77.54

36.99

2011

63.20

35.65

2012

50.86

24.61

2013

(Jan to Mar)

23.68

11.49

Property Taxation Exemptions

Ceisteanna (167)

Michelle Mulherin

Ceist:

167. Deputy Michelle Mulherin asked the Minister for Finance the circumstances in which the Revenue Commissioners will deem a residential property to be uninhabitable and the owner not liable for the local property tax; and if he will make a statement on the matter. [26900/13]

Amharc ar fhreagra

Freagraí scríofa

For Local Property Tax (LPT) purposes a residential property is defined as any building or structure (or part of a building) which is used as, or is suitable for use as, a dwelling. If a residential property is suitable for use as a dwelling but is unoccupied, it is still liable to LPT based on the valuation of the property. However, if the property is not suitable for use as a dwelling, it is not liable for LPT. LPT is a self-assessed tax. If a property owner considers that her or his property is not suitable for use as a dwelling, s/he should notify the Revenue Commissioners without delay and arrange to provide relevant supporting documentation; for example, photographic evidence, a report from a suitably qualified person such as a surveyor or an engineer. Based on the information provided by the property owner, Revenue will consider the claim and make a decision on the matter.

Each case will be considered on its own merits and it is therefore not possible to provide a prescriptive list of criteria that would need to be met for a property to be deemed unsuitable for use as a dwelling. However, a property owner should consider whether the property is habitable by reference to the structure of the building, including whether the property has a roof, windows and doors, sanitary facilities, and services (water or electricity supply turned off or temporarily disconnected would not necessarily mean that a residential property is uninhabitable).

The deadline for filing LPT Returns has now passed and I am informed by the Revenue Commissioners that later this month they will begin writing to customers who have not met their LPT obligations. Where a customer has not filed his or her LPT Return, Revenue will pursue collection of the Revenue Estimate of LPT as notified in the letter that accompanied the LPT Return. A range of collection options will be utilised by Revenue, including mandatory deduction at source from salary or occupational pension. Therefore, it is most important that any property owner who has not yet filed their LPT return, on the basis that they consider that the property is not suitable for use as a dwelling, should contact Revenue immediately via the LPT Helpline at 1890 200 255, if they have not already done so.

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