Written answer
Tax Code
657. Deputy Pádraig O'Sullivan asked the Tánaiste and Minister for Finance the estimated amount of corporation tax foregone to the Exchequer in each of the years 2019 to 2025 inclusive by reason of the carry forward of trading losses under section 396 of the Taxes Consolidation Act 1997 by institutions which received State support during the banking crisis; and if he will make a statement on the matter. [60167/26]
Comment on this
Due to Revenue’s obligation to protect the confidentiality of taxpayer data, as provided for in Section 851A of the Taxes Consolidation Act 1997, it is not possible to provide the data requested by the Deputy due to the low number of taxable entities involved.
Further detail is available in Revenue’s Statistical Disclosure Control Protocol, published on the Revenue website at www.revenue.ie/en/corporate/information-about-revenue/statistics/about/statistical-disclosure-control.aspx
Under the Irish corporation tax regime, companies can use trading losses in a variety of ways. If a company sustains trading losses in an accounting period, they can be offset against trading income for the same accounting period, and trading income for the immediately preceding accounting period. Any unused trading losses may be utilised against non-trading income, including chargeable gains, on a value basis. A trading loss may also be surrendered to group companies, subject to certain conditions and restrictions. Any unused trading losses can be carried forward, without time limit, against trading income of the same trade in future accounting periods.
The carry forward of loss relief recognises the fact that business cycles run over a longer period than just a single year and that it would be inequitable to tax profits in one year and not allow loss relief in the next. The treatment of losses in Ireland is a long-standing feature of our tax system and is a standard feature of the tax systems in OECD countries.
Supporting the banks during the crisis imposed a huge economic burden on the State, so it is appropriate that the banking sector make a contribution to the State’s economic recovery. Therefore, in 2013, a bank levy was introduced. This levy was subsequently extended a number of times.