Irish Finance Minister Brian Cowen moved to restrict the number of tax exemptions
that can be claimed by wealthy individuals living in Ireland as part of the
government's 2006 Budget, which was announced on Wednesday.
The new measure is being introduced from 1 January 2007, and will limit the
use of tax reliefs by individuals whose taxable income would have exceeded EUR250,000
in the absence of such reliefs. This will involve a calculation that broadly
operates by restricting the maximum amount of "specified reliefs"
to the greater of EUR250,000 or 50% of "recomputed gross income".
Any relief denied in a particular year can be carried forward. This cap will
also apply to artists' income, although the artist income tax exemption up to
a limit of EUR 250,000 will remain in place.
In other loophole closures, the majority of property based tax incentive schemes
are also to be discontinued, subject to transitional measures, and the remittance
basis of taxation which provides favourable taxation treatment in respect of
individuals resident in Ireland, but who are either not domiciled or not ordinarily
resident in the country, will be abolished on income earned in Ireland from
January 1, 2006.
The subject of tax reliefs has been the source of much controversy in recent
weeks, since it emerged that several millionaires had managed to whittle down
their tax liability to virtually nothing. According to figures released by the
Finance Ministry in September covering the 'short' tax years of 2001 and 2002,
30 individuals with incomes of more than EUR1 million per year who were resident
in Ireland for tax purposes paid only small amounts of tax, and in some cases
no tax at all. An additional 67 individuals whose income was between EUR500,000
and EUR1 million paid tax at the 20% marginal rate, while a further 10 people
paid no tax.
Cowen also announced the termination of the tax exemption for income from the sale
of certain stallion and greyhound services, which has been abolished with effect from
31 July 2008. Following discussions with the European Commission, a replacement
regime might be introduced.
In other measures affecting business: companies' capital duty has been abolished
for transactions undertaken on or after 7 December 2005; the use of interest
relief on borrowings arising on certain transactions between related companies
will be restricted and will become effective on transactions undertaken on or
after December 7, 2005; and certain restrictions on the offset by companies
of losses arising from capital allowances on the leasing of certain plant machinery
will be relaxed.