706. Deputy Pádraig O'Sullivan asked the Tánaiste and Minister for Finance if he will set out, in respect of banks (details supplied), the deferred tax asset recognised in each institution's most recently published annual report arising from unused trading losses, together with the corporation tax charge and the corporation tax actually paid as disclosed in each of those reports; and if he will make a statement on the matter. [60170/26]

I note the Deputy has asked me to set out the deferred tax asset recognised in each of the above banks most recent annual reports arising from unused trading losses. I understand this request to refer to the line item commonly recorded as “unutilised tax losses” within the deferred tax asset category, which can also be described as “carried forward tax losses”.

According to the consolidated group financial statements that form part of the 2025 published annual reports for these banks:

AIB recognised €1,975 million of unutilised tax losses per Note 25 “Deferred Taxation” on page 298. Of this amount €1,729 million is attributed to unutilised Irish tax losses.

BOI recognised €466 million of unutilised tax losses per Note 32 “Deferred Tax” on page 386. Of this amount €411 million is attributed to Irish tax losses carried forward.

PTSB recognised €307 million of carried forward tax losses per Note 2b on page 320[1]. It is noted that this figure relates to tax losses generated in the legal entity itself, with no deferred tax asset recognised on tax losses carried forward in any other Group company.

The links to the relevant annual reports are set out as follows.

AIB:www.aib.ie/content/dam/frontdoor/investorrelations/docs/resultscentre/annualreport/2025/aib-group-plc-afr-report-2025.pdf

Bank of Ireland : investorrelations.bankofireland.com/app/uploads/Annual-Report-HoldCo-2025-WEB-high-res.pdf

PTSB: www.permanenttsbgroup.ie/~/media/Files/P/Ptsb-CORP/documents/result-centre/annual-interim/2025/ptsbgh-annual-report-2025.pdf

[1] Note 25 on Deferred Taxation on page 349 gives an overall Deferred Tax Asset figure of €318 million of which the amount of carried forward tax losses per Note 2b is understood to be a part.

It is important to understand that the State has received value from these deferred tax assets through its share sales.

I note the Deputy has also asked me to set out the corporation tax charge reported in the most recent annual reports for these banks, understood to refer to the current year Irish corporation tax charge. Irish corporation tax may arise despite unutilised tax losses within a corporate group where the tax losses carried forward do not shelter profits made in all of the entities within a corporate group.

The following amounts are reported in respect of current year Irish corporation tax charges in the consolidated group financial statements that form part of the 2025 published annual reports for these banks (see link above):

Finally, I note that the Deputy has asked me to comment on the corporation tax actually paid by these banks. Section 851A of the Taxes Consolidation Act 1997 precludes the Revenue Commissioners from directly or indirectly disclosing taxpayer-specific information to third parties unless this is specifically provided for in legislation. I am therefore unable to comment directly on the amount of tax paid by these banks.

The Deputy will recall that, 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/department-of-finance/publications/technical-note-on-the-potential-consequences-of-changes-to-the-treatment-of-corporation-tax-loss-relief-in-respect-of-banks/).

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.