Many of the Republic’s wealthiest people cut their income tax liabilities by claiming an aggregate €755 million in tax credits and reliefs in 2024, the State spending watchdog has found.
After examining how Revenue manages the affairs of almost 2,000 high-wealth individuals (HWIs), the Comptroller & Auditor General (C&AG) attributed “relatively low amounts of tax due” from many of to the amount of taxable income earned and the use of credits and reliefs.
Some €576 million of the €755 million in credits and reliefs claimed in 2024 related to loss reliefs, the C&AG’s annual report said.
Loss reliefs allow taxpayers to cut their liability by setting off losses in trade, professions or employment against profits and gains.
The report said Revenue finalised just over 1,800 HWI “interventions” between 2019 and 2025, resulting in a combined €172 million additional yield of tax, interest and penalties.
“The percentage of yielding cases in those years ranged between 26 per cent and 42 per cent. This is typically higher than the yield rate for Revenue’s compliance activity across all taxpayers,” said the C&AG.
Citing opportunities for aggressive tax planning, the Comptroller & Auditor General called on the Revenue to use monthly reviews to produce new annual reports on high-wealth individuals’ compliance risk. The Revenue was also told to “ensure” such taxation is reappraised in an appropriate timeframe.
The tax authority agreed with both recommendations.
All high-wealth individuals were subject to a comprehensive appraisal when assigned to the HWI case base, with reappraisals carried out whenever “high value transactions, significant events or other risks arise”.
Still, the C&AG found the Revenue had no mechanism “for monitoring the extent to which reappraisals are being completed” when there were no big transactions or significant events.
The Comptroller & Auditor General found the tax affairs of 1,901 high-wealth individuals were managed by the Revenue as of July, with 3,500 people and entities treated as secondary cases.
Secondary cases were taxpayers connected with a high-wealth individual, including family members who do not have net assets greater than €20 million, as well as non-trading partnerships and companies, foundations, trusts and co-ownerships.
In 2024, net income tax totalling €27.6 billion was due in relation to all taxpayers, including €421 million in relation to the 1,558 HWIs who filed an income tax return. This excluded capital gains tax and capital acquisitions tax.
The effective tax rate for high-wealth individuals in 2024 was 33 per cent – almost double the 17 per cent rate for all income tax taxpayers. “The average income tax due from HWIs was almost €270,200 while the average amount of income tax due from all income tax taxpayers was just under €8,400,” said the C&AG.
The report went on to note “significant variations” in the effective tax rates between high-wealth individuals, with 24 per cent of the total €421 million HWI income tax return coming from the top 20 high-wealth individuals. “The relatively low amounts of tax due by many HWIs reflect the amount of taxable income earned in the year and the utilisation of credits and reliefs.”
