In a newly published report for 2023, Revenue says 127 people were covered by the restriction, generating an extra €13.6m in income tax. This was 26 fewer people than in 2022, and €3.7m less in tax.
The numbers have been falling steadily for more than a decade.
The High-Income Individuals’ Restriction (HIIR) was first introduced in January 2007 and originally designed to ensure that people with incomes above €500,000 paid an effective income tax rate of 20pc.
In 2010, after the financial crash, the threshold at which restrictions began was reduced to €125,000 from €250,000, and the goal became an effective tax rate of about 30pc for those earning €400,000 or more.
The restriction captured far more high-net-worth individuals in its early years. In 2010, for example, there were 1,544 people covered by the restriction, and it raised an extra €80.1m in income tax.
By 2013, there were still 904 people covered, and an additional €60.4m was raised. However, both numbers have been declining steadily since then, and the 127 individuals covered in 2023 is the lowest since the restriction was brought in. The extra tax of €13.5m is also the lowest so far.
The Revenue report says that 46 individuals with an adjusted income of €400,000 or more, and to whom the full restriction applies, paid an average income tax rate of 29.7pc in 2023. When the Universal Social Charge (USC) is factored in, the tax rate rises to 39.1pc.
Adjusted income is Revenue’s calculation of a person’s income before certain tax reliefs are used to reduce their tax bill.
“This broadly meets the objective set out for the measure,” the report says. “The estimated additional income tax involved is €10.7m, a 305pc increase on the tax that would otherwise have been paid if the restriction had not applied.
“Furthermore, of those 46 individuals, 27 who would not otherwise have paid income tax in 2023 are brought into the tax net.”
Meanwhile, 81 people with an adjusted income of up to €400,000, to whom the restriction applies on a graduated basis, paid an average effective income tax rate of 17.5pc. When USC was added, they paid 25.6pc.
Revenue said the €2.8m extra tax they paid was a 350pc increase on what would have been paid if there was no restriction. Of the 81 people, 45 who would not otherwise have paid income tax in 2023 were brought into the tax net.
The reliefs that are restricted include property tax incentives, and the artists’ tax exemption. They also include reliefs on historic building, and on interest paid on loans used to buy a partnership.
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