I am sure the Taoiseach's attention has been drawn to the figures released to my colleague, Deputy Burton, in respect of the liability of different categories of taxpayers. They show that 242 persons with incomes between €100,000 and €1 million per year pay no tax at all and that 41 people with incomes in excess of €500,000 per year pay no tax. Is the Taoiseach satisfied that people on the national minimum wage are subject to taxation and are taxed while the super wealthy who earn in excess of €500,000 per year can arrange their affairs so that they are liable for no tax at all?

Does the Taoiseach agree that the response of the tax advice industry is not very compelling? They ask why we should bother when all these schemes will finish in 2006. The Taoiseach will know that we have had announcements like that down the years but that the schemes have never finished. For example, Deputy McCreevy, when presenting the 2003 budget, said, "A series of tax incentives, many of them involving capital allowances have been extended in the past for a number of years and several are due to expire on 31 December 2004". He went on to say what they were and then he said, "All of these schemes, without exception, are to end on 31 December 2004". He came in the following year with his budget for 2004 and extended them to 31 July 2006.

Does the Taoiseach think the existence of these schemes is justified in all circumstances? Does he intend to extend them again? Does he think it fair, irrespective of the merit of the schemes, that an individual in such a super earning bracket should be capable of reducing his or her tax to zero? Does he think an effective minimum rate of tax, as was proposed yesterday by Deputy Burton, would be fair in a society where persons on the national minimum wage must pay some tax while super high rollers can organise their affairs so that they have, legitimately, no tax liability?

I have seen the figures. I saw the contents of Deputy Cowen's reply which said that of 10,828 PAYE income earners of €100,000 or more per annum, 10,741 were liable for tax at a rate of 42%, 40 were liable at a rate of 20% and 47 had a nil net income tax liability. Of 9,240 self-employed people with incomes of more than €100,000, 8,936 were liable for tax at a rate of 42%, 109 were liable at a rate of 20% and 195 had a nil net income tax liability.

My answer to Deputy Rabbitte's question as to whether I think it fair that people play the system to that extent is that I do not. Tax incentives and reliefs are not tax loopholes or avoidance mechanisms in the strict sense. They are introduced by successive Governments to stimulate investment. All Governments have generally introduced or continued various tax reliefs with the aim of stimulating investment and helping employment, particularly in designated regions. From that point of view they serve a useful purpose. They are not intended to be used so cleverly that people pay no tax.

What is the best way of dealing with such avoidance? Deputy Rabbitte and I have read reports of the Revenue Commissioners which state that when there is a minimum tax rate the tax compliance industry will play to that figure and one will find more people at it. I am not in the business so I do not know, but that is what they continually say. It is my view that it is better to take the alternative approach and to limit the tax schemes, shelters and allowances which allow the present position.

There are several reasons why some persons have a nil liability. Tax relief for pension contributions is quite legal. Losses due to capital allowances and business investment is the main reason for tax relief. I have not seen a survey of the people referred to in the Minister's reply but I would bet my bottom dollar that their reliefs arise from capital allowances. That has been the case since the first of these allowances were introduced in 1978. There are also tax breaks such as the business expansion scheme, film and urban renewal reliefs. Such schemes play a big part in stimulating the economy. Still, if people on €100,000 can have a nil liability, I do not believe that is the aim.

The former and current Ministers for Finance have referred to changing or eliminating perhaps not all but as many of these allowances as possible. The Revenue has shown in some of its own figures that the most attractive tax relief measure is the one concerning film production. We remember the furore and lobbying last year about the film production tax relief. Everybody in the country became a supporter of that measure for three weeks before the budget.

It is not that somebody earning €100,000 can have a zero tax liability but that somebody on €1 million can. If the Taoiseach agrees with me that it is inequitable, will he take the opportunity in the budget and the finance Bill to do something about it? In answer to a parliamentary question, the former Minister for Finance, Deputy McCreevy, was unable to say what 30 of those schemes would cost the taxpayer. Therefore, we do not know what tax is being forgone or the cost to the taxpayer. He said he could not tell us.

At the same time, however, in response to another parliamentary question tabled by my colleague, Deputy Lynch, it transpired that a pensioner who managed to squirrel together the wherewithal to open a special savings investment account, SSIA, is now being advised by the new Minister for Social and Family Affairs that it will be taken into account for means assessment purposes. Pensioners who worked all their lives on relatively modest salaries and who open SSIAs, which is Government policy, will now find those accounts being taken into account for the purpose of assessing means. On the other hand, somebody earning €1 million can arrange their affairs so that they pay no tax.

I agree with the Taoiseach. I do not say that all the schemes are wrong in all respects. The point I ask the Taoiseach to address is that nobody who invests in or avails of these schemes ought to escape with a zero tax contribution to the Exchequer. Has the Taoiseach a view on the minimum effective tax rate question?

Deputy Rabbitte has asked me what will happen concerning this question. The 2003 budget announced the termination of various property investment reliefs which are now being strictly adhered to. The termination date was extended in the Finance Act to provide for an ordinary wind-down of existing schemes to which people were tied contractually, or where they had planning difficulties, and in all the other cases that have been made.

The top 400 earners study carried out by the Revenue Commissioners in 2002, which are the only figures we have, indicates that there was an increasingly effective tax rate of high earners compared with the last year Revenue examined, which was the 1999-2000 period. I am informed that trend has continued. That is because as reliefs, shelters and allowances are being closed off, they cannot be used. It is clear that some high earners continue to achieve substantial reductions in their tax liabilities as a result of these reliefs. As I have already said, the most generous one, which involves the least risk, is the film relief that, rightly or wrongly, we included last year.

The Revenue Commissioners' study indicated that property-based capital allowances continued to be the chief instrument used by high income earners. That has been the case for many years. Most of these allowances will die out at the end of 2006. The issue is being examined by the tax strategy group and will also be examined in the context both of the budget and the finance Bill.