The Bill gives effect to the Budget announcement of a Domicile Levy. From 1 January 2010 certain individuals who are Irish citizens and Irish domiciled in a tax year will pay a Levy of €200,000.
Specifically the levy will apply where the individual has:
- Irish located property greater than €5 million,
- worldwide income in excess of €1 million and
- an Irish income tax liability less than €200,000,
The Bill clarifies that Irish property is all property located in Ireland but does not include shares in a trading company or a holding company which derives the greater part of their value from subsidiary trading companies.
The individual's Irish income tax liability the year will be allowed as a credit in arriving at the amount of the domicile levy for that year. The levy will apply irrespective of where they live or where they are tax resident.