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Dáil

Written answer

Tax Reliefs

683. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance the estimated revenue raised by introducing a 25% or 50% cap, respectively, on corporation tax relief utilised in a single year by all banks, in first and full-year terms. [55293/26]

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Simon Harris Tánaiste and Minister for Finance Fine Gael

I understand that the Deputy is referring to corporation tax relief for losses.

As the Deputy is aware, loss relief for corporation tax is a long-standing feature of the Irish corporate tax system and a standard feature of corporation tax systems in most OECD countries. It recognises the fact that a business cycle runs over several years and that it would be unfair to tax income earned in one year and not allow relief for losses incurred in another. Loss relief works by allowing a deduction for losses incurred in one accounting period against profits earned in another period.

The value of these tax losses to the State has been and is being realised through share sales. The banks’ share prices have recognised a certain value for the tax losses and, as such, the State has received value for the balance of tax losses as share sales are completed.

I am advised by Revenue that the estimated revenue raised by introducing a 25 percent and 50 percent cap, respectively, on corporation tax loss relief utilised in a single year by all banks would be dependent on the profitability of the banks in any particular year and the amount of losses available to the banks.

The estimated losses restricted and amounts that would have been raised in 2024, the most recent year in respect of which data are available, is presented in the table below:

It is not possible to provide data for 2025 as most banks have not yet submitted their tax returns, which for most are due on 23rd September 2026.

In 2018, Department of Finance officials produced a detailed technical note for the Committee on Finance, Public Expenditure and Reform and Taoiseach on the subject of both bank losses and corporation tax losses more generally (see www.gov.ie/en/publication/436ff7-technical-note-on-the-potential-consequences-of-changes-to-the-treat/). The technical note considered in some detail the potential implications of restricting the use of losses carried forward, or the introduction of a specific time limit or “sunset clause” on loss relief for Irish banks, for the wider banking sector, or for the corporate sector as a whole.

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