Only 13 super-rich paid the Domicile Levy in 2021

The number of super-rich people who pay the €200,000 Domicile Levy each year has fallen to 13, despite an appreciable growth in the net wealth of the richest 5 per cent of people in Ireland.

Figures supplied by the Revenue Commissioners show that a total of €1.6 million was collected from the levy in 2021 from 13 non-domiciled Irish residents.

However, the actual returns from the levy have been described in the past by the Commission on Tax and Welfare as “negligible”.

The 2021 out-turn represented a fall from 2020, when 15 people paid the levy (paying €2.4 million to the exchequer), and in 2019, when 17 people paid it. Those who pay the levy can write off any Irish income tax paid against the levy.

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The information was supplied by Minister for Finance Michael McGrath in response to a parliamentary question tabled by Labour Finance spokesman Ged Nash.

The levy was introduced in 2010 as a way of getting super-wealthy Irish people who live abroad for tax reasons to make a contribution to the exchequer.

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The Domicile Levy is charged on all Irish-domiciled individuals who meet the qualifying criteria. The levy applies if an individual is Irish-domiciled for a tax year, whether resident or non-resident, and has Irish-located capital/assets greater than €5 million in the tax year, has worldwide income in excess of €1 million for the tax year, and has an Irish income tax liability of less than €200,000 for the tax year.

Taxpayers are entitled to credit any Irish income tax paid for that year against the levy.

In the first year of its operation in 2010, some 25 individuals filed returns. By 2012 the number had fallen to 15, and has remained in that range in every succeeding year since.

Mr Nash has called for the levy to be reformed so that more non-domiciled Irish residents with significant wealth can make a contribution to the State.

“When looking at wealth taxes, the report from the Commission on Tax and Welfare put it well when it said ‘the low collection rate of the Domicile Levy suggests some underperformance’,” Mr Nash said.

“This is putting it mildly. That report went on to say that the revenue collected from the levy has been negligible. The figures I have received bear this out.

[ Many of Ireland's wealthiest taxed at rate below average worker ]

“It is striking that both the revenue generated and the number of people who pay the levy has remained strangely consistent over the years. This all the more surprising given the very significant growth in net wealth concentrated in the top 5 per cent in Ireland in the last decade, as reported by the Central Bank Evolution of Irish Household Wealth Inequality Since 2013 report published last November.

“The Domicile Levy of itself is an imperfect way of taxing super-wealth. In the interests of equity, the levy should be reviewed and on our way to the design of a proper net wealth tax, the existing wealth taxes we do have such as Capital Acquisitions and Capital Gains Taxes need to be restructured in order to contribute a greater proportion of Ireland’s tax take,” he added.

In his response to the parliamentary question, Mr McGrath said it would not be possible to accurately provide an estimate of the additional revenue that would be raised from increasing the levy to €400,000.

The Limerick billionaire JP McManus has paid the tax in the past. In 2016, he told a US court he paid the domicile levy in 2012.