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									CRMS 2784.10


Ms. Eimear Lavelle,
Committee Secretariat,
Committee of Public Accounts,
Leinster House,
Dublin 2.

31 March 2010



Dear Ms. Lavelle,


Thank you for your letter of 18 March and I attach herewith the information requested by
you.

Please do not hesitate to contact me if you require any further information.



Yours sincerely,




______________
Josephine Feehily
Accounting Officer
1. Offshore Amnesty
A note on the number of people who have made returns under the offshore assets inquiry
who had already availed of the two tax amnesties of the 1990’s.




Under the 2004 voluntary disclosure scheme for Offshore Assets a total of 45 people
claimed the benefits of the 1993 Amnesty provisions. Following investigation of the cases
the benefits of the Amnesty were withdrawn in 13 of the 45 cases and the amounts paid
under the amnesty were treated as payments on account against the full liabilities. In the
13 cases the taxpayers settled their liabilities on the basis of full tax, statutory interest and
100% penalties for the pre-Amnesty periods and the provisions as regards publication as a
tax defaulter were applied. The remaining 32 cases were found to have correctly availed of
the amnesty.
2. Disposal of seized contraband goods
A note on the methods used for the disposal of seized goods such as cigarettes, drugs,
alcohol and fuel.




There are various methods used for disposal depending on the goods involved. Disposal
methods used for major seizure items are set out below.

(1) Cigarettes and tobacco products.
 All such products are shredded on the State Warehouse premises under Revenue staff
supervision. The shredded product is then removed for deep burial in landfill sites such as
Oxegen's landfill facility at Ballymount, Dublin 12. The contractors used are all ISO
14001 accredited.

(2) Drugs
Seizures of controlled drugs are safely disposed of by incineration - using a procedure
similar to An Garda Síochána - when they are no longer required to be retained as
evidence.

(3)Alcohol.
Alcohol is separated from its original containers, bottles, and cans and removed to the
Dublin City Council treatment plant at Ringsend. The original containers are then
removed to be recycled.

(4) Fuel
Seized fuel is brought to the State Warehouse and stored in a bonded area. Tenders are
invited for non-contaminated fuel which is then sold to the highest bidder. Contaminated
fuel is collected by an ISO accredited contractor and is recycled through the road
construction industry.

(5) Vehicles
Vehicles that are in fair to good condition are sold by tender to the highest bidder. The
remainder are sent to be scrapped and an End of Life Certificate obtained in each case.
3. Capital Allowances

A detailed note on purpose tests in place for the draw down of capital allowances and the
amount that has been clawed back by Revenue, where buildings are now not used for
original stated purpose.




1. Timing of capital allowances

1.1. Qualifying periods

Most of the property-based tax incentive schemes have a termination date. This is the date
by which construction and refurbishment work have to be carried out if the expenditure
that is attributable to that work is to qualify for capital allowances. A building may not be
completed by the relevant termination date and further development can be carried out
beyond that date. However, any expenditure that is attributable to this additional work
does not qualify for capital allowances. The termination dates for particular schemes refer
only to the carrying out of qualifying development work and not to the date by which
buildings have to be purchased, put into use for the required purpose or capital allowances
claimed. There are no time limits for purchase and use of a building or for claiming capital
allowances.

1.2. When capital allowances can be claimed

In general, capital allowances are claimed by the person who purchases a completed
building and not by the person who carries out the development work. When the
allowances can be claimed depends on the type of allowances that are available and on
whether they are claimed by owner-occupiers or lessors. Different types of buildings and
schemes attract different types of capital allowances.

In general, a building must be completed and in use for a particular purpose before capital
allowances can be claimed. However, there is a particular type of accelerated capital
allowance, known as an ‘initial allowance’, that can be claimed at the time that
expenditure is incurred on development work. This initial allowance can only be claimed
at this early stage where a building is to be occupied when it is completed for the purposes
of carrying on a trade by the person who incurs the development expenditure. Where a
building is to be leased, the initial allowance cannot be claimed until such time as the
building has been let on an arm’s length basis on bona fide commercial terms. This is
unlikely to happen before a building has been completed, or substantially completed.

With the exception of childcare facilities, the various sectoral-based tax incentive
buildings such as tourist accommodation (including hotels) and the health-related facilities
do not attract initial allowances. The area-based schemes, such as the urban, town and
rural renewal schemes, have this allowance. For these schemes an initial allowance of
50% of the qualifying expenditure incurred is available. The remaining 50% of the
qualifying expenditure is then claimed over a number of years.
In relation to partly completed buildings, such as office blocks and hotels, being granted
capital allowances, as explained in the preceding paragraphs this is only likely to occur in
the case of owner-occupiers who intend to carry on a trade in the building. Most tax
incentive buildings are purchased by passive investors and leased. By way of illustration,
for 2007 (the latest year for which data is available) 1,885 claims for €130.8 million in
capital allowances were made in respect of commercial buildings under the urban, rural
and town renewal schemes. Of this, 77% of the claims and 85% of the amount of capital
allowances claimed were accounted for by passive investors. Such investors cannot claim
initial allowances until the building has been leased. Initial allowances that have been
granted in the case of owner-occupiers can be clawed back if, when a building comes to be
used, it is not used for the required purpose at that stage.

2. Purpose tests

There is no requirement to secure Revenue approval before capital allowances can be
claimed in respect of expenditure incurred on the development or purchase of a tax
incentive building. Any person who satisfies the conditions pertaining to a particular tax
incentive scheme, as set out in the relevant legislation or guidelines, can claim the
appropriate capital allowances on the annual return of income under the self-assessment
system. These conditions may include being approved or certified by bodies other than
Revenue. In addition, planning authorities may attach conditions relating to the permitted
use of a building to the grant of planning permission.

2.1. Types of purpose tests

The extent to which a ‘purpose test’, in the sense of a building having to be in use for a
specified purpose, exists in relation to establishing entitlement to capital allowances varies
considerably between the different incentive schemes.

Some of the health-related facilities (hospitals, mental health centres, sports injury clinics)
have a purpose test in that annual certification is required from the Health Services
Executive before the building can qualify for capital allowances.

In contrast to these health-related facilities, the area-based incentive schemes, such as the
urban, rural and town renewal schemes, have no specific purpose tests. Capital allowances
are generally given for what are termed ‘commercial’ buildings. These are essentially
buildings that are used for business purposes and would include the office blocks referred
to during the Committee proceedings. The only purpose tests are that the building must be
occupied for the purposes of a trade by the owner of the building or be leased on an arm’s
length basis on bona fide commercial terms. Owner-occupiers are generally free to carry
on any trade and there is no requirement in the case of leased buildings for the lessee to
carry on a trade.

Other types of building are required to be used for a specified purpose but don’t have to
satisfy an actual ‘test’, for example, childcare facilities, airport buildings or buildings used
for market gardening. While other categories of building require certification before they
can qualify for capital allowances, for example, buildings at park and ride facilities and
multi-storey car parks are certified by the relevant local authority and the Minister for
Enterprise, Trade and Employment certifies companies that occupy buildings in the
Enterprise Area Scheme.
Certain types of buildings are required to satisfy an ongoing test, for example, holiday
cottages must be included on an annual basis in the appropriate Fáilte Ireland register and
hotels are required to be registered annually by Fáilte Ireland where the expenditure on the
hotel was incurred on or after 3 February 2005 and a valid application for full planning
permission had not been made by 31 December 2004.

2.2. Buildings not used for original stated purpose

A building can cease to be used for the required purpose without giving rise to a clawback
of capital allowances already given. Such clawbacks only occur where there is a
‘balancing event’. This is explained in section 3 below. However, entitlement to the
ongoing annual capital allowances depend on a building being in use for the specified
purpose at the end of each of the years for which allowances are available. Thus, these
annual allowances cannot be claimed where, for example, a hotel is not in use for the trade
of hotel-keeping at the end of the relevant year. In the case of all buildings that qualify for
capital allowances, the Tax Acts allow for the possibility that buildings may, for whatever
reason, not always be in use for the required purpose.

3. Clawback of capital allowances

There are essentially two kinds of scenarios that may give rise to a clawback of capital
allowances, i.e. not holding onto a building for the required number of years and not
satisfying all of the required conditions for claiming capital allowances.

3.1. Balancing events

The Tax Acts specify a limited number of events, known as ‘balancing events’ that can
trigger a clawback of capital allowances already given. These events are –

      The sale of the building.
      The ending of a leasehold interest (where the lessor is entitled to allowances).
      The demolition or destruction of the building or its ceasing altogether to be used
       for any purpose.

These events have no effect where they occur outside of a specified period of the building
starting to be used for the relevant purpose. This specified period is known as the ‘tax-life’
of a building and varies in length depending on the particular building. For example, most
of the tax incentive hotels have a tax-life of 7 years, childcare facilities have a tax-life of
15 years and offices in the area-based schemes have a tax-life of 13 years.

When one of these events occurs there is a balancing adjustment to the capital allowances
given to a person that can take the form of either additional allowances being given or
some, or all, of the allowances already given being clawed back. Balancing adjustments
are designed to ensure that a person is only compensated for his or her net capital outlay.
Thus, the cost of the building, the capital allowances given and any sales proceeds or
compensation or insurance monies are taken into account. If the value received exceeds
the amount of the capital allowances still to be claimed (i.e. the portion of the original
capital expenditure not yet written down) the person has effectively been
overcompensated for their original outlay and there is a clawback of some, or all, of the
allowances that have already been granted. The converse is that the value received for the
building might actually be lower than the amount of the capital allowances still to be
claimed so that the person is effectively 'out of pocket' and has to be further compensated
by being given the remaining unclaimed capital allowances, i.e. no clawback arises in this
situation.

It is important to realise that only certain specified events trigger the balancing
adjustment. Thus, for example, a hotel could simply cease trading, or be used for
alternative purposes, without being sold so that there is no balancing event. In this
situation there would be no clawback but the remainder of the annual allowances could
not be claimed.

3.2. Allowances incorrectly claimed

It may happen that a person could claim, under the self-assessment system, capital
allowances to which he or she was not entitled. For example, a building may not have
been in use for the required purpose at the end of the year or the required conditions for a
particular incentive scheme may not have been met. Any allowances incorrectly given are
clawed back. Such discoveries may arise from Revenue’s normal audit and assurance
checks or may be brought to Revenue’s attention by the claimant.

3.3. Data on allowances clawed back

The type of information requested by the Committee on the amount of capital allowances
that have been clawed back is not captured by Revenue.

Both the return of income for self-employed individuals (form F11) and companies (form
CT1) capture data on the amount of capital allowances clawed back (known as ‘balancing
charges’) under the ‘trade’ section of the return. However, this ‘balancing charge’ entry
does not distinguish between normal capital allowances given to traders and tax incentive
scheme allowances. Nor does it distinguish between capital allowances given as
compensation for the wear and tear suffered by plant and machinery and allowances given
for the construction or purchase of buildings. Nor is it broken down by sector or type of
building.

The ‘rental income’ sections of the return forms contain a single entry for ‘capital
allowances’. Any allowances that are due and any that are being clawed back are ‘netted-
off’ to give a single net figure for allowances due. This net figure would also include
capital allowances given in relation to the acquisition of plant and machinery that is used
in the rented building. Therefore, it is not possible to identify the amount of any capital
allowances that have been clawed back from passive investors.

Capital allowances that are clawed back as a result of audit or assurance checks are not
separately identified but are included in the overall audit settlement figure.
4. Refunds of Tax in respect of property losses
A note on the amount of tax that has been refunded to property and construction
companies who have made substantial claims for losses




Repayments of tax associated solely with losses are not separately identifiable in the
statistics from repayments made for other reasons.
The following table provides a breakdown of the total refunds of corporation tax to
property and construction companies in 2009

Amounts of Corporation Tax refunded in 2009

                  Sector               Amount
                                       €m
                  Property/Real Estate 65.0
                  activities
                  Construction         95.4


The sector identifier used on the tax records is based on the 4 digit “NACE code (Rev. 1)”
which is an internationally recognised economic activity code system. The NACE codes
are not essential for the assessment and collection of taxes and duties and the correct
allocation and maintenance of these codes is subject to the limit of available resources.
NACE code classifications on tax records are compiled by reference to the primary area of
economic activity reported by individual and corporate taxpayers on their own behalf and
the taxes collected are allocated to those codes without reference to the precise economic
activity which generated them. While the accuracy of the NACE codes on tax records is
sufficient to underpin broad sector-based analyses there will undoubtedly be some
inaccuracies at individual level. This should be borne in mind when considering the
information provided.
The figures provided for the estimated yield from each sector are confined to those
activities which are defined within the NACE codes associated with the sector headings
shown and do not include the yield from activities and businesses identified under other
NACE codes which could be related, either in whole or in part, to the sectors listed. An
example of these would be architecture, engineering and the manufacture of products used
in construction are not included in the heading construction above.
5. Under-declaration by the professional services category
A note on the outcome of the random audits that found that 35% of those involved in
professional services under-declared their tax liabilities and the proportion of those who
have been serious cases of under-declaration.




The 35% of professional services cases referred to is to be found in Figure 43 of the
Comptroller and Auditor General’s Annual Report, 2008.

This figure derived from an analysis of 66 random audit cases that were classified as
‘professional services’ under the NACE coding systems. Forty three (43) of these cases
were found to have no tax liability. The 5 most serious of the remaining 23 cases
produced yields (including all tax periods) in excess of €20,000 each.

Full details of the yield from the 23 cases are set out in the accompanying table.

As stated in the response to Question 4, the sector identifier used on the tax records is
based on the 4 digit “NACE code (Rev. 1)” which is an internationally recognised
economic activity code system. The NACE codes are not essential for the assessment and
collection of taxes and duties and the correct allocation and maintenance of these codes is
subject to the limit of available resources. NACE code classifications on tax records are
compiled by reference to the primary area of economic activity reported by individual and
corporate taxpayers on their own behalf and the taxes collected are allocated to those
codes without reference to the precise economic activity which generated them. While the
accuracy of the NACE codes on tax records is sufficient to underpin broad sector-based
analyses there will undoubtedly be some inaccuracies at individual level. This should be
borne in mind when considering the information provided.
Table: ANALYSIS OF PROFESSIONAL SERVICES


                                                           Additional Yields
       NACE                                                (Outside relevant
       Code               Description          Total (€)     time period)*
  1     7031    Auctioneer                         28,288              35,847
  2     7460    Security Services                  27,291              12,855
  3     7221    Software Engineer                  24,981
  4     7481    Photographer                       10,817              22,971
  5     7020    Rental Income                        9,579
  6     7032    Auctioneer                           9,086
  7     7411    Solicitor                            6,617              9,014
  8     7260    Computer Services                    6,271
  9     7414    Public Relations                     6,251
 10     7020    Hardware Supplier                    4,976              2,195
 11     7420    Consultant: Environmental            3,714              2,666
 12     7420    Architectural Services               3,547
 13     7012    Property Sales                       3,172
 14     7414    Business Consultant                  2,973
 15     7011    Property Developer                   2,579              2,440
 16     7412    Accountant                           2,100              1,211
 17     7420    Architectural Service                1,846
 18     7020    Surgeon                              1,576
 19     7411    Solicitor                            1,299             50,350
 20     7412    Accountant                           1,000
 21     7412    Book-keeping services                  470
 22     7250    Services: Office Equipment             269
 23     7020    Rental Income                          230
                TOTAL                             158,932            139,549


*The relevant accounting period for the 2007 random audit programme was accounting
periods ending in the calendar year 2005.
6. Tax paid by Different Sectors
A note showing tax receipts and underlying income by income bands sub-divided by
sector.




The latest relevant sector-based information available on tax and related income is derived
from income tax returns filed for the income tax year 2007 and represents about 95% of
all returns expected at the time the data were compiled for analytical purposes.
On this basis a breakdown on a sector basis of the combined numbers of income
earners, both PAYE and self-employed, is tabulated in the accompanying
appendix.
The income ranges shown in the tables relate to Gross Income as defined in Revenue
Statistical Reports.
The sector identifier used on the tax records is based on the 4-digit NACE code
(Rev. 1) which, as mentioned in the reply to question 4 above, is an internationally
recognised economic activity code system.
A married couple, which has elected or has been deemed to have elected for joint
assessment, is counted as one tax unit.
Figures for "Income Tax" shown in the tables relate to income tax liability
calculated on the basis of tax returns filed for 2007 by self-employed income
earners and by employers on behalf of their employees.
                                                                                   Appendix
                                          (i)
                               INCOME TAX 2007

                                  ALL SECTORS
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                  Totals

   From         To          Number       % of     Income       % of     Tax        % of
     €          €           of cases     total     €'m         total    €'m        total


       -        10,000      450,751      19.06      2,085.64    2.34        2.59    0.02
  10,000        12,000       86,861       3.67        956.03    1.07        2.42    0.02
  12,000        15,000      124,781       5.28      1,684.58    1.89        6.49    0.05
  15,000        17,000       86,461       3.66      1,384.39    1.55        6.16    0.05
  17,000        20,000      144,250       6.10      2,668.34    2.99       25.09    0.20
  20,000        25,000      231,548       9.79      5,204.00    5.84      150.61    1.23
  25,000        27,000       84,772       3.58      2,204.07    2.47       94.70    0.77
  27,000        30,000      119,116       5.04      3,393.17    3.81      174.86    1.42
  30,000        35,000      172,392       7.29      5,592.96    6.27      359.31    2.92
  35,000        40,000      145,888       6.17      5,462.12    6.13      454.75    3.70
  40,000        50,000      212,417       8.98      9,480.38   10.63    1,058.81    8.62
  50,000        60,000      139,504       5.90      7,628.34    8.55    1,042.25    8.48
  60,000        75,000      136,451       5.77      9,124.74   10.23    1,419.36   11.55
  75,000       100,000      114,006       4.82      9,767.64   10.95    1,811.25   14.74
 100,000       150,000       72,268       3.06      8,609.43    9.65    1,938.07   15.77
 150,000       200,000       19,748       0.83      3,372.09    3.78      863.55    7.03
 200,000       275,000       10,943       0.46      2,539.95    2.85      677.52    5.51
Over           275,000       13,291       0.56      8,014.60    8.99    2,198.27   17.89

Totals                     2,365,448     100      89,172.47 100        12,286.06 100
                                                                                  Appendix
                                          (ii)
                               INCOME TAX 2007

               AGRICULTURE, HUNTING AND FORESTRY
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                     Totals

   From          To           Number        % of    Income      % of     Tax      % of
     €           €            of cases      total    €'m        total    €'m      total


       -        10,000          15,738      14.00       78.08     1.63     0.13    0.03
  10,000        12,000           3,581       3.19       39.45     0.82     0.16    0.04
  12,000        15,000           5,297       4.71       71.65     1.50     0.52    0.12
  15,000        17,000           3,797       3.38       60.78     1.27     0.57    0.13
  17,000        20,000           6,280       5.59      115.97     2.42     1.36    0.32
  20,000        25,000           9,716       8.64      218.10     4.56     4.87    1.13
  25,000        27,000           3,447       3.07       89.58     1.87     2.49    0.58
  27,000        30,000           4,902       4.36      139.62     2.92     4.44    1.03
  30,000        35,000           7,665       6.82      248.84     5.20     8.98    2.08
  35,000        40,000           6,947       6.18      260.17     5.44    10.53    2.44
  40,000        50,000          11,164       9.93      499.95    10.45    28.04    6.51
  50,000        60,000           8,605       7.66      471.66     9.86    35.15    8.15
  60,000        75,000           9,633       8.57      645.54    13.50    61.96   14.37
  75,000       100,000           8,773       7.80      752.07    15.73    90.60   21.02
 100,000       150,000           5,061       4.50      597.22    12.49    89.87   20.85
 150,000       200,000             993       0.88      168.68     3.53    29.38    6.82
 200,000       275,000             386       0.34       88.35     1.85    16.48    3.82
Over           275,000             425       0.38      236.77     4.95    45.55   10.57

Totals                        112,410        100      4,782.48 100       431.09 100
                                                                                    Appendix
                                          (iii)
                               INCOME TAX 2007

                                     FISHING
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                       Totals

   From           To           Number             % of    Income     % of     Tax   % of
     €            €            of cases           total    €'m       total    €'m   total


       -         10,000            550            20.55       2.42     2.49   0.00 0.03
  10,000         12,000             80             2.99       0.88     0.90   0.01 0.11
  12,000         15,000            125             4.67       1.69     1.73   0.02 0.18
  15,000         17,000            119             4.45       1.91     1.97   0.02 0.21
  17,000         20,000            172             6.43       3.18     3.27   0.06 0.65
  20,000         25,000            276            10.31       6.26     6.45   0.27 3.05
  25,000         27,000             79             2.95       2.06     2.11   0.07 0.80
  27,000         30,000            113             4.22       3.20     3.30   0.15 1.67
  30,000         35,000            198             7.40       6.39     6.58   0.35 4.00
  35,000         40,000            150             5.60       5.63     5.79   0.36 4.09
  40,000         50,000            233             8.70      10.38    10.68   0.77 8.86
  50,000         60,000            147             5.49       7.98     8.21   0.74 8.47
  60,000         75,000            175             6.54      11.65    11.99   1.42 16.26
  75,000        100,000            142             5.30      12.22    12.58   1.97 22.51
 100,000        150,000             75             2.80       8.92     9.17   1.29 14.82
 150,000        200,000             18             0.67       3.12     3.21   0.47 5.43
 200,000        275,000             10             0.37       2.26     2.33   0.23 2.62
Over            275,000             15             0.56       7.03     7.24   0.54 6.24

Totals                            2,677           100        97.19 100        8.73 100
                                                                                     Appendix
                                          (iv)
                               INCOME TAX 2007

                           MINING AND QUARRING
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                      Totals

   From           To           Number        % of        Income     % of     Tax     % of
     €            €            of cases      total        €'m       total    €'m     total


       -        10,000             536            8.54       2.88     1.05    0.00    0.00
  10,000        12,000             143            2.28       1.57     0.57    0.00    0.00
  12,000        15,000             174            2.77       2.35     0.86    0.00    0.01
  15,000        17,000             149            2.37       2.39     0.87    0.00    0.01
  17,000        20,000             249            3.97       4.59     1.68    0.05    0.15
  20,000        25,000             467            7.44      10.58     3.86    0.32    0.91
  25,000        27,000             207            3.30       5.38     1.97    0.25    0.71
  27,000        30,000             341            5.43       9.71     3.55    0.52    1.48
  30,000        35,000             522            8.31      16.97     6.20    1.06    3.02
  35,000        40,000             498            7.93      18.68     6.82    1.53    4.37
  40,000        50,000             846           13.47      37.96    13.86    3.75   10.72
  50,000        60,000             688           10.96      37.68    13.76    4.68   13.37
  60,000        75,000             707           11.26      47.27    17.26    7.16   20.47
  75,000       100,000             518            8.25      43.83    16.00    8.01   22.91
 100,000       150,000             186            2.96      21.56     7.87    4.84   13.83
 150,000       200,000              29            0.46       4.86     1.78    1.25    3.59
 200,000       275,000              11            0.18       2.44     0.89    0.71    2.02
Over           275,000                8           0.13       3.16     1.15    0.84    2.41

Totals                           6,279           100       273.86 100        34.98 100
                                                                                  Appendix
                                          (v)
                               INCOME TAX 2007

                               MANUFACTURING
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                     Totals

   From          To           Number       % of     Income       % of    Tax      % of
     €           €            of cases     total     €'m         total   €'m      total


       -        10,000          28,640     12.50        143.59    1.74     0.05    0.00
  10,000        12,000           5,894      2.57         64.71    0.79     0.10    0.01
  12,000        15,000           8,604      3.76        116.22    1.41     0.28    0.03
  15,000        17,000           6,644      2.90        106.45    1.29     0.31    0.03
  17,000        20,000          12,984      5.67        240.91    2.92     2.08    0.22
  20,000        25,000          25,889     11.30        584.19    7.09    17.82    1.86
  25,000        27,000          10,948      4.78        284.75    3.45    12.65    1.32
  27,000        30,000          15,392      6.72        438.34    5.32    23.12    2.42
  30,000        35,000          21,783      9.51        706.32    8.57    46.51    4.87
  35,000        40,000          17,223      7.52        644.25    7.82    54.71    5.73
  40,000        50,000          25,158     10.98      1,122.79   13.62   123.39   12.91
  50,000        60,000          16,659      7.27        910.67   11.05   119.72   12.53
  60,000        75,000          15,422      6.73      1,029.32   12.49   154.02   16.12
  75,000       100,000          11,379      4.97        969.86   11.77   179.07   18.74
 100,000       150,000           5,151      2.25        603.74    7.33   141.44   14.80
 150,000       200,000             913      0.40        154.23    1.87    43.23    4.52
 200,000       275,000             270      0.12         62.42    0.76    19.13    2.00
Over           275,000             133      0.06         59.19    0.72    17.95    1.88

Totals                        229,086       100       8,241.96 100       955.58 100
                                                                                 Appendix
                                         (vi)
                               INCOME TAX 2007

                ELECTRICITY, GAS AND WATER SUPPLY
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                     Totals

   From          To           Number       % of     Income      % of     Tax     % of
     €           €            of cases     total     €'m        total    €'m     total


       -        10,000             363      4.15         2.10     0.36     0.00 0.00
  10,000        12,000              96      1.10         1.06     0.18     0.00 0.00
  12,000        15,000             133      1.52         1.77     0.31     0.00 0.00
  15,000        17,000              87      0.99         1.40     0.24     0.00 0.00
  17,000        20,000             174      1.99         3.22     0.56     0.03 0.02
  20,000        25,000             308      3.52         6.99     1.21     0.20 0.17
  25,000        27,000             174      1.99         4.53     0.79     0.17 0.15
  27,000        30,000             256      2.93         7.29     1.26     0.37 0.33
  30,000        35,000             392      4.48        12.72     2.21     0.80 0.70
  35,000        40,000             398      4.55        14.91     2.59     1.33 1.17
  40,000        50,000             889     10.16        40.05     6.95     5.18 4.55
  50,000        60,000             935     10.68        51.62     8.95     8.50 7.48
  60,000        75,000           1,411     16.12        94.96    16.47    17.42 15.32
  75,000       100,000           1,681     19.21       144.64    25.09    30.41 26.76
 100,000       150,000           1,203     13.75       143.04    24.81    35.73 31.44
 150,000       200,000             207      2.37        34.94     6.06    10.01 8.81
 200,000       275,000              35      0.40         7.88     1.37     2.44 2.14
Over           275,000              10      0.11         3.43     0.59     1.08 0.95

Totals                           8,752      100        576.52 100        113.67 100
                                                                                  Appendix
                                         (vii)
                               INCOME TAX 2007

                                CONSTRUCTION
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                     Totals

   From          To           Number       % of     Income       % of    Tax      % of
     €           €            of cases     total     €'m         total   €'m      total


       -        10,000          38,572      16.43       202.57    2.63     0.16    0.02
  10,000        12,000           9,125       3.89       100.43    1.30     0.41    0.05
  12,000        15,000          14,046       5.98       189.71    2.46     1.32    0.16
  15,000        17,000           9,748       4.15       156.05    2.03     1.39    0.16
  17,000        20,000          15,187       6.47       280.90    3.65     4.54    0.53
  20,000        25,000          25,274      10.76       568.28    7.38    20.83    2.45
  25,000        27,000           9,558       4.07       248.51    3.23    12.40    1.46
  27,000        30,000          13,465       5.73       383.56    4.98    21.86    2.57
  30,000        35,000          20,265       8.63       656.95    8.53    45.04    5.30
  35,000        40,000          16,018       6.82       599.08    7.78    50.86    5.98
  40,000        50,000          23,142       9.86     1,032.54   13.41   113.33   13.33
  50,000        60,000          13,900       5.92       758.62    9.86    98.70   11.61
  60,000        75,000          12,426       5.29       829.44   10.78   121.84   14.33
  75,000       100,000           8,462       3.60       720.85    9.36   130.21   15.32
 100,000       150,000           3,998       1.70       471.56    6.13   104.90   12.34
 150,000       200,000             874       0.37       148.53    1.93    36.95    4.35
 200,000       275,000             371       0.16        85.41    1.11    21.52    2.53
Over           275,000             385       0.16       264.75    3.44    63.83    7.51

Totals                        234,816       100       7,697.75 100       850.10 100
                                                                                 Appendix
                                         (viii)
                               INCOME TAX 2007

WHOLESALE AND RETAIL TRADE; REPAIR OF MOTOR VEHICLES,
  MOTORCYCLES AND PERSONAL AND HOUSEHOLD GOODS
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                     Totals

   From          To           Number        % of    Income      % of     Tax     % of
     €           €            of cases      total    €'m        total    €'m     total


       -        10,000        107,231       30.73      482.53     5.42   0.11 0.01
  10,000        12,000          15,236       4.37      167.45     1.88   0.24 0.03
  12,000        15,000          21,661       6.21      292.41     3.28   0.73 0.08
  15,000        17,000          15,719       4.50      251.83     2.83   0.63 0.07
  17,000        20,000          25,931       7.43      479.13     5.38   4.05 0.45
  20,000        25,000          37,863      10.85      849.87     9.54 26.41 2.91
  25,000        27,000          12,923       3.70      335.72     3.77 15.26 1.68
  27,000        30,000          16,461       4.72      468.51     5.26 25.45 2.81
  30,000        35,000          21,114       6.05      683.05     7.67 45.08 4.98
  35,000        40,000          14,711       4.22      549.80     6.17 43.97 4.85
  40,000        50,000          19,349       5.54      862.07     9.68 87.96 9.71
  50,000        60,000          12,540       3.59      685.70     7.70 84.11 9.28
  60,000        75,000          11,918       3.42      795.82     8.93 116.19 12.82
  75,000       100,000           9,179       2.63      783.18     8.79 146.41 16.16
 100,000       150,000           4,968       1.42      589.59     6.62 132.21 14.59
 150,000       200,000           1,219       0.35      207.19     2.33 52.96 5.84
 200,000       275,000             535       0.15      123.30     1.38 32.35 3.57
Over           275,000             412       0.12      300.00     3.37 91.96 10.15

Totals                        348,970        100      8,907.17 100       906.11 100
                                                                                 Appendix
                                         (ix)
                               INCOME TAX 2007

                         HOTELS AND RESTAURANTS
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                     Totals

   From          To           Number       % of     Income      % of     Tax     % of
     €           €            of cases     total     €'m        total    €'m     total


       -        10,000          69,624     41.88       305.73    10.11     0.10 0.05
  10,000        12,000           9,095      5.47       100.05     3.31     0.15 0.07
  12,000        15,000          13,148      7.91       177.52     5.87     0.39 0.19
  15,000        17,000           9,612      5.78       153.92     5.09     0.40 0.19
  17,000        20,000          15,761      9.48       291.02     9.63     2.32 1.13
  20,000        25,000          16,670     10.03       370.61    12.26    10.92 5.33
  25,000        27,000           4,317      2.60       112.15     3.71     5.10 2.49
  27,000        30,000           4,813      2.90       136.81     4.53     7.32 3.57
  30,000        35,000           5,921      3.56       191.58     6.34    12.00 5.86
  35,000        40,000           3,922      2.36       146.51     4.85    10.60 5.18
  40,000        50,000           4,672      2.81       207.80     6.87    18.27 8.92
  50,000        60,000           2,676      1.61       146.25     4.84    15.72 7.68
  60,000        75,000           2,336      1.41       156.14     5.17    20.11 9.82
  75,000       100,000           1,818      1.09       155.54     5.15    25.18 12.30
 100,000       150,000           1,109      0.67       131.50     4.35    24.94 12.18
 150,000       200,000             351      0.21        60.47     2.00    12.87 6.29
 200,000       275,000             200      0.12        46.53     1.54    10.01 4.89
Over           275,000             206      0.12       132.64     4.39    28.36 13.85

Totals                        166,251       100       3,022.75 100       204.75 100
                                                                                  Appendix
                                          (x)
                               INCOME TAX 2007

            TRANSPORT, STORAGE AND COMMUNICATION
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                     Totals

   From          To           Number       % of     Income      % of     Tax      % of
     €           €            of cases     total     €'m        total    €'m      total


       -        10,000          13,937      11.16       66.81     1.44     0.15    0.03
  10,000        12,000           3,387       2.71       37.25     0.80     0.14    0.03
  12,000        15,000           5,620       4.50       76.25     1.64     0.40    0.08
  15,000        17,000           4,378       3.51       70.07     1.51     0.45    0.09
  17,000        20,000           7,468       5.98      138.26     2.98     1.29    0.25
  20,000        25,000          13,374      10.71      300.82     6.48     7.85    1.53
  25,000        27,000           5,163       4.14      134.27     2.89     5.13    1.00
  27,000        30,000           7,356       5.89      209.48     4.51     9.57    1.86
  30,000        35,000          10,909       8.74      354.14     7.63    20.35    3.95
  35,000        40,000          10,081       8.08      377.32     8.12    28.45    5.53
  40,000        50,000          14,275      11.43      636.73    13.71    61.84   12.02
  50,000        60,000           9,397       7.53      513.60    11.06    60.44   11.74
  60,000        75,000           9,047       7.25      604.21    13.01    83.59   16.24
  75,000       100,000           6,492       5.20      553.69    11.92    98.47   19.13
 100,000       150,000           3,023       2.42      355.48     7.65    79.07   15.36
 150,000       200,000             601       0.48      101.80     2.19    26.04    5.06
 200,000       275,000             205       0.16       47.13     1.01    12.90    2.51
Over           275,000             126       0.10       66.75     1.44    18.52    3.60

Totals                        124,839       100       4,644.09 100       514.65 100
                                                                                 Appendix
                                         (xi)
                               INCOME TAX 2007

                         FINANCIAL INTERMEDIATION
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                     Totals

   From          To           Number       % of     Income      % of     Tax     % of
     €           €            of cases     total     €'m        total    €'m     total


       -        10,000          19,589     14.02        84.81     1.62   0.05 0.01
  10,000        12,000           6,726      4.81        74.25     1.42   0.03 0.00
  12,000        15,000           8,574      6.14       114.79     2.19   0.09 0.01
  15,000        17,000           4,719      3.38        75.40     1.44   0.07 0.01
  17,000        20,000           8,756      6.27       162.42     3.10   0.55 0.07
  20,000        25,000          15,038     10.76       338.10     6.46   7.22 0.91
  25,000        27,000           5,745      4.11       149.39     2.86   5.94 0.75
  27,000        30,000           8,161      5.84       232.51     4.44 11.69 1.47
  30,000        35,000          11,637      8.33       377.15     7.21 23.86 3.01
  35,000        40,000           9,183      6.57       343.30     6.56 29.61 3.74
  40,000        50,000          12,289      8.79       548.29    10.48 68.75 8.67
  50,000        60,000           7,776      5.57       425.15     8.13 69.93 8.82
  60,000        75,000           7,434      5.32       496.74     9.49 93.75 11.83
  75,000       100,000           6,324      4.53       543.61    10.39 118.46 14.94
 100,000       150,000           5,057      3.62       604.80    11.56 154.98 19.55
 150,000       200,000           1,482      1.06       252.62     4.83 73.21 9.23
 200,000       275,000             720      0.52       166.22     3.18 53.03 6.69
Over           275,000             520      0.37       242.44     4.63 81.51 10.28

Totals                        139,730       100       5,232.00 100       792.73 100
                                                                                 Appendix
                                         (xii)
                               INCOME TAX 2007

           REAL ESTATE, RENTING AND BUSINESS ACTIVITIES
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                   Totals

   From          To          Number       % of     Income       % of    Tax      % of
     €           €           of cases     total     €'m         total   €'m      total


       -        10,000         65,543     19.28        296.83    1.79      1.24 0.04
  10,000        12,000         11,493      3.38        126.43    0.76      0.53 0.02
  12,000        15,000         15,971      4.70        215.87    1.30      1.04 0.04
  15,000        17,000         10,976      3.23        175.76    1.06      0.77 0.03
  17,000        20,000         18,476      5.43        342.04    2.07      3.33 0.12
  20,000        25,000         31,802      9.35        715.85    4.33     22.84 0.82
  25,000        27,000         12,145      3.57        315.70    1.91     14.99 0.53
  27,000        30,000         16,812      4.94        479.16    2.90     27.06 0.97
  30,000        35,000         24,419      7.18        792.18    4.79     56.25 2.01
  35,000        40,000         19,086      5.61        714.43    4.32     64.74 2.31
  40,000        50,000         26,931      7.92      1,203.42    7.27    145.52 5.19
  50,000        60,000         18,641      5.48      1,020.48    6.17    149.77 5.35
  60,000        75,000         19,322      5.68      1,294.08    7.82    214.03 7.64
  75,000       100,000         18,582      5.47      1,601.02    9.67    307.65 10.98
 100,000       150,000         15,265      4.49      1,839.62   11.12    414.12 14.78
 150,000       200,000          5,565      1.64        954.87    5.77    235.61 8.41
 200,000       275,000          3,577      1.05        830.82    5.02    209.74 7.49
Over           275,000          5,411      1.59      3,631.26   21.94    932.70 33.29

Totals                       340,017      100      16,549.82 100        2,801.93 100
                                                                                  Appendix
                                         (xiii)
                               INCOME TAX 2007

 PUBLIC ADMINISTRATION AND DEFENCE; COMPULSORY SOCIAL
                       SECURITY
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                   Totals

   From          To          Number       % of    Income       % of     Tax       % of
     €           €           of cases     total    €'m         total    €'m       total


       -        10,000         19,650      9.05        93.61     1.04      0.04    0.00
  10,000        12,000          5,846      2.69        64.72     0.72      0.06    0.00
  12,000        15,000          9,669      4.46       130.65     1.45      0.19    0.02
  15,000        17,000          5,686      2.62        90.97     1.01      0.11    0.01
  17,000        20,000          8,459      3.90       156.43     1.74      0.62    0.05
  20,000        25,000         16,250      7.49       367.40     4.08      7.50    0.61
  25,000        27,000          6,416      2.96       167.05     1.86      6.05    0.49
  27,000        30,000         11,459      5.28       326.74     3.63     14.92    1.21
  30,000        35,000         17,037      7.85       554.87     6.16     33.00    2.67
  35,000        40,000         21,071      9.71       791.55     8.79     71.20    5.75
  40,000        50,000         31,673     14.60     1,410.38    15.67    177.48   14.33
  50,000        60,000         20,101      9.26     1,100.08    12.22    174.25   14.07
  60,000        75,000         19,474      8.97     1,300.70    14.45    231.12   18.67
  75,000       100,000         14,844      6.84     1,270.73    14.12    242.00   19.54
 100,000       150,000          8,335      3.84       980.20    10.89    223.80   18.07
 150,000       200,000            860      0.40       142.88     1.59     39.82    3.22
 200,000       275,000            140      0.06        31.62     0.35      9.79    0.79
Over           275,000             42      0.02        20.70     0.23      6.24    0.50

Totals                       217,012       100      9,001.27 100        1,238.19 100
                                                                                  Appendix
                                         (xiv)
                               INCOME TAX 2007

                                   EDUCATION
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                     Totals

   From          To           Number        % of    Income       % of    Tax      % of
     €           €            of cases      total    €'m         total   €'m      total


       -        10,000         11,196       23.61        43.83    2.58     0.03    0.01
  10,000        12,000          1,641        3.46        18.03    1.06     0.04    0.02
  12,000        15,000          2,226        4.69        29.99    1.77     0.13    0.05
  15,000        17,000          1,415        2.98        22.63    1.33     0.11    0.04
  17,000        20,000          2,288        4.83        42.30    2.49     0.37    0.15
  20,000        25,000          3,503        7.39        78.61    4.63     2.06    0.81
  25,000        27,000          1,396        2.94        36.29    2.14     1.46    0.57
  27,000        30,000          1,849        3.90        52.70    3.10     2.75    1.09
  30,000        35,000          2,890        6.10        93.82    5.53     6.40    2.52
  35,000        40,000          2,756        5.81       103.30    6.08     9.58    3.78
  40,000        50,000          4,656        9.82       207.84   12.24    27.13   10.69
  50,000        60,000          2,984        6.29       162.81    9.59    25.93   10.22
  60,000        75,000          2,962        6.25       198.88   11.72    36.20   14.27
  75,000       100,000          3,300        6.96       280.96   16.55    60.05   23.67
 100,000       150,000          1,844        3.89       220.84   13.01    52.30   20.61
 150,000       200,000            364        0.77        61.17    3.60    16.85    6.64
 200,000       275,000            106        0.22        23.78    1.40     6.94    2.74
Over           275,000             37        0.08        19.87    1.17     5.39    2.12

Totals                         47,413       100       1,697.64 100       253.74 100
                                                                                 Appendix
                                         (xv)
                               INCOME TAX 2007

                         HEALTH AND SOCIAL WORK
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                   Totals

   From          To          Number       % of    Income       % of     Tax      % of
     €           €           of cases     total    €'m         total    €'m      total


       -        10,000         20,815     12.23       104.64     1.39      0.06 0.00
  10,000        12,000          6,319      3.71        69.52     0.93      0.12 0.01
  12,000        15,000          7,839      4.61       105.72     1.41      0.22 0.02
  15,000        17,000          5,495      3.23        88.07     1.17      0.21 0.02
  17,000        20,000          9,602      5.64       177.61     2.36      1.19 0.10
  20,000        25,000         16,268      9.56       365.92     4.87      8.65 0.73
  25,000        27,000          5,925      3.48       154.06     2.05      5.63 0.47
  27,000        30,000          9,008      5.29       256.79     3.42     12.63 1.06
  30,000        35,000         14,460      8.50       469.91     6.25     30.72 2.58
  35,000        40,000         13,069      7.68       489.33     6.51     44.53 3.74
  40,000        50,000         20,266     11.91       905.49    12.05    116.66 9.80
  50,000        60,000         12,351      7.26       672.71     8.95    106.10 8.91
  60,000        75,000          9,958      5.85       664.57     8.85    113.34 9.52
  75,000       100,000          8,287      4.87       709.10     9.44    140.18 11.78
 100,000       150,000          5,082      2.99       606.89     8.08    144.61 12.15
 150,000       200,000          1,723      1.01       296.43     3.95     77.76 6.53
 200,000       275,000          1,566      0.92       368.31     4.90     97.15 8.16
Over           275,000          2,122      1.25     1,008.22    13.42    290.46 24.40

Totals                       170,155      100       7,513.30 100        1,190.20 100
                                                                                  Appendix
                                         (xvi)
                               INCOME TAX 2007

OTHER COMMUNITY, SOCIAL AND PERSONAL SERVICE ACTIVITIES
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                     Totals

   From          To           Number       % of     Income      % of     Tax      % of
     €           €            of cases     total     €'m        total    €'m      total


       -        10,000          26,943      26.13      123.98     4.38     0.06    0.02
  10,000        12,000           5,372       5.21       59.05     2.09     0.21    0.07
  12,000        15,000           7,551       7.32      102.03     3.60     0.61    0.20
  15,000        17,000           5,087       4.93       81.41     2.87     0.65    0.21
  17,000        20,000           7,635       7.40      140.95     4.98     1.84    0.59
  20,000        25,000          11,095      10.76      248.35     8.77     7.89    2.52
  25,000        27,000           3,608       3.50       93.86     3.31     4.28    1.37
  27,000        30,000           4,670       4.53      132.94     4.69     7.23    2.31
  30,000        35,000           6,342       6.15      205.37     7.25    13.79    4.41
  35,000        40,000           4,894       4.75      183.35     6.47    15.73    5.03
  40,000        50,000           6,636       6.44      295.89    10.45    32.47   10.38
  50,000        60,000           3,999       3.88      218.84     7.73    29.90    9.56
  60,000        75,000           3,701       3.59      247.64     8.75    38.45   12.30
  75,000       100,000           3,018       2.93      258.25     9.12    48.86   15.62
 100,000       150,000           1,703       1.65      201.17     7.10    45.78   14.64
 150,000       200,000             454       0.44       77.54     2.74    20.41    6.53
 200,000       275,000             202       0.20       46.04     1.63    12.72    4.07
Over           275,000             199       0.19      115.12     4.07    31.84   10.18

Totals                        103,109       100       2,831.79 100       312.74 100
                                                                                 Appendix
                                          (xvii)
                               INCOME TAX 2007

                         ACTIVITIES OF HOUSEHOLDS
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                      Totals

   From           To           Number         % of     Income     % of     Tax   % of
     €            €            of cases       total     €'m       total    €'m   total


       -        10,000             261         20.81       1.44     1.95    0.00 0.01
  10,000        12,000              61          4.86       0.67     0.90    0.00 0.01
  12,000        15,000             100          7.97       1.36     1.84    0.01 0.05
  15,000        17,000              95          7.58       1.52     2.05    0.01 0.08
  17,000        20,000             106          8.45       1.94     2.63    0.02 0.13
  20,000        25,000             120          9.57       2.67     3.62    0.06 0.41
  25,000        27,000              32          2.55       0.83     1.13    0.03 0.21
  27,000        30,000              45          3.59       1.28     1.74    0.04 0.29
  30,000        35,000              66          5.26       2.16     2.93    0.13 0.83
  35,000        40,000              42          3.35       1.57     2.13    0.09 0.61
  40,000        50,000              53          4.23       2.37     3.21    0.22 1.42
  50,000        60,000              34          2.71       1.84     2.50    0.22 1.41
  60,000        75,000              45          3.59       3.04     4.12    0.46 3.00
  75,000       100,000              48          3.83       4.20     5.69    0.78 5.07
 100,000       150,000              53          4.23       6.55     8.89    1.44 9.44
 150,000       200,000              27          2.15       4.59     6.22    1.19 7.79
 200,000       275,000              22          1.75       5.09     6.90    1.44 9.43
Over           275,000              44          3.51      30.65    41.55    9.16 59.82

Totals                           1,254         100        73.76 100        15.31 100
                                                                                  Appendix
                                          (xviii)
                               INCOME TAX 2007

          EXTRA-TERRITORIAL ORGANIZATIONS AND BODIES
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                       Totals

   From           To           Number           % of    Income     % of     Tax   % of
     €            €            of cases         total    €'m       total    €'m   total


       -         10,000              51         14.05       0.26     1.69   0.00 0.00
  10,000         12,000              15          4.13       0.16     1.05   0.00 0.03
  12,000         15,000              20          5.51       0.27     1.76   0.00 0.00
  15,000         17,000               9          2.48       0.14     0.93   0.00 0.00
  17,000         20,000              24          6.61       0.44     2.86   0.00 0.10
  20,000         25,000              29          7.99       0.66     4.27   0.02 0.82
  25,000         27,000              13          3.58       0.34     2.19   0.02 0.59
  27,000         30,000              36          9.92       1.02     6.58   0.05 1.97
  30,000         35,000              46         12.67       1.49     9.62   0.10 3.76
  35,000         40,000              31          8.54       1.15     7.45   0.11 4.08
  40,000         50,000              29          7.99       1.28     8.24   0.14 5.15
  50,000         60,000              15          4.13       0.80     5.19   0.13 4.59
  60,000         75,000              18          4.96       1.21     7.83   0.20 7.25
  75,000        100,000              10          2.75       0.86     5.53   0.16 5.91
 100,000        150,000              10          2.75       1.20     7.75   0.32 11.37
 150,000        200,000               3          0.83       0.53     3.40   0.13 4.65
 200,000        275,000               1          0.28       0.23     1.45   0.08 2.76
Over            275,000               3          0.83       3.44    22.20   1.30 46.97

Totals                             363          100        15.50 100        2.77 100
                                                                                  Appendix
                                         (xix)
                               INCOME TAX 2007

                      ALL OTHER SECTORS/UNKNOWN
  Distribution of (i) number of incomes, (ii) gross income charged and (iii) tax, by
                               range of gross income.
  Range of gross
     income                                                   Totals

   From          To          Number       % of    Income       % of     Tax       % of
     €           €           of cases     total    €'m         total    €'m       total


       -        10,000         11,512     10.25        49.52     0.62      0.42    0.03
  10,000        12,000          2,751      2.45        30.35     0.38      0.20    0.01
  12,000        15,000          4,023      3.58        54.35     0.68      0.53    0.03
  15,000        17,000          2,726      2.43        43.67     0.54      0.48    0.03
  17,000        20,000          4,698      4.18        87.03     1.09      1.39    0.08
  20,000        25,000          7,606      6.77       170.73     2.13      4.88    0.29
  25,000        27,000          2,676      2.38        69.59     0.87      2.79    0.17
  27,000        30,000          3,977      3.54       113.49     1.42      5.68    0.34
  30,000        35,000          6,726      5.99       219.05     2.73     14.89    0.90
  35,000        40,000          5,808      5.17       217.77     2.72     16.79    1.01
  40,000        50,000         10,156      9.04       455.16     5.68     47.91    2.89
  50,000        60,000          8,056      7.17       441.85     5.51     58.25    3.51
  60,000        75,000         10,462      9.31       703.49     8.78    108.09    6.52
  75,000       100,000         11,149      9.93       963.05    12.02    182.78   11.02
 100,000       150,000         10,145      9.03     1,225.56    15.29    286.41   17.27
 150,000       200,000          4,065      3.62       697.63     8.71    185.40   11.18
 200,000       275,000          2,586      2.30       602.15     7.51    170.89   10.30
Over           275,000          3,193      2.84     1,869.19    23.33    571.02   34.42

Totals                       112,315      100       8,013.63 100        1,658.81 100
7. Tax System
A note on the amount of the tax lost where workers are placed in some form of off-shore
tax arrangement (using the Brookfield example).




The Irish taxation system, in line with general international practice, provides that –
(a) individuals who are resident in the State for tax purposes are taxable here on their
    worldwide income; and
(b) individuals who are not resident here for tax purposes are taxable here only on income
    arising in the State and on income derived from working in the State.

The fact that an Irish resident individual is employed by or paid through an off-shore
structure does not in any way diminish the liability of such an individual to Irish tax.

In cases where workers are engaged by, or paid through, an off-shore structure, a number
of issues may arise such as –

      is the individual employed or self-employed?
      if employed, who is the employer?
      are structures interposed between the worker and ultimate engager?
      are such interposed structures put in place to seek to obviate an employer’s
       statutory obligations as regards matters such as tax, PAYE/PRSI, employee
       entitlements and health and safety?

These are questions of fact that can only be determined on a case by case basis having
regard to the circumstances and evidence pertaining to each case.

The interposing of companies/agencies between workers and the ultimate engager may
not, of itself, obviate the need for the ultimate engager to comply with normal statutory
obligations. For example, despite the structure used, it may be the case that, given the
level of control, direction, obligations, prohibitions, rosters, etc. exercised by the ultimate
engager on the individual engaged, one could reasonably conclude that the relation
between the ultimate engager and the individual is one of employer and employee.
However, each case has to be examined on its merits and it may ultimately be a matter for
the courts to determine the true relationship between the parties.

Where these off-shore structures are identified, it is not so much a question of quantifying
tax loss but rather a matter of examining each case to determine whether or not the
structure put in place seeks to distance the ultimate engager from the individuals carrying
out the work. The purpose of such an examination being to determine the legitimacy of
those structures and whether any liability to Irish tax exists and, if so, whether an
obligation to operate Irish PAYE on payments made exists and, most importantly, where
such a liability or obligation exists, to seek to secure the tax/PRSI due.

								
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