Ireland Corporation Tax Concentration

Around half of the corporation tax paid to the Exchequer comes from just three multinational companies. That is the Department of Finance’s own finding, and it sits underneath almost every number in Budget 2027.

The budget documents, laid before the Oireachtas on 6 October 2026, forecast a general government surplus of €6.7 billion this year and €9.5 billion in 2027.

The same tables tell a second story. The Department estimates that €18.8 billion of this year’s corporation tax, and €22.9 billion of next year’s, is “potentially transitory”: money it cannot be confident will keep arriving. Take it out and the surplus becomes a deficit of €12.1 billion in 2026 and €13.4 billion in 2027.

In both years, the money the Department is unsure about is larger than the whole surplus.

Year	Headline surplus	Potentially transitory corporation tax	Balance without it
2025	€10.7bn	€16.8bn	−€6.1bn
2026 (forecast)	€6.7bn	€18.8bn	−€12.1bn
2027 (forecast)	€9.5bn	€22.9bn	−€13.4bn

General government basis. Source: Department of Finance, Budget 2027 Economic and Fiscal Outlook, Table 15.

How big corporation tax has become

Revenue’s annual report on the tax, published on 7 May 2026, puts net corporation tax receipts for 2025 at €32.9 billion, paid by 84,591 companies. That figure excludes the once-off Apple money (see below) and represents underlying growth of 17 per cent on 2024.

The payments are far from evenly spread. Foreign-owned multinationals paid €28.8 billion, or 87 per cent of the total. The ten largest corporate groups alone paid €19.5 billion, which Revenue says left their share “remaining steady at 59%”.

On that underlying basis, Revenue says corporation tax was “almost one third” of all tax receipts in 2025.

The Department forecasts corporation tax of €34.1 billion this year, a 3.5 per cent rise on last year’s underlying figure, and €39.1 billion in 2027. It describes the Exchequer as “increasingly reliant on a handful of products” and warns that “any decline in profitability could put a (potentially large) dent in corporate tax revenues.”

Part of the swing between 2026 and 2027 is about timing. The Department links this year’s softer figure in part to payments under Pillar II, the OECD-agreed global minimum tax, which it says “look set to be backloaded to next year”.

The Apple money is counted separately

The Apple State aid case adds a once-off layer. After the Court of Justice of the European Union gave its final judgment in September 2024, the Department of Finance says €12,677 million was paid to Revenue as tax and a further €1,567 million in interest and gains went to the Exchequer in cash. That is about €14.2 billion in all. The escrow account closed on 13 May 2025.

Both Revenue and the Department strip these receipts out of their underlying figures. Revenue’s tables show net corporation tax of €39.1 billion in 2024 including the CJEU money, against €28.1 billion without it. When the Government published its updated National Development Plan, it said the plan drew on “once-off funds, including the ECJ Escrow Fund”.

Where the savings go

The State has two funds designed to bank some of the windfall. Both are managed by the National Treasury Management Agency.

The Future Ireland Fund receives 0.8 per cent of GDP each year from 2024 to 2035. It is meant to support spending from 2041 onwards, when the costs of an ageing population are expected to rise.

The Infrastructure, Climate and Nature Fund receives €2 billion a year from 2024 to 2030. The Department describes it as “a counter-cyclical buffer” for major shocks, and it can also pay for designated climate and nature projects, up to a cumulative €3.15 billion by 2030.

Budget 2027 plans transfers of €4.5 billion to the Future Ireland Fund and €2 billion to the climate fund this year. Next year the total rises to €7.8 billion. The Department also notes that up to €3¼ billion can be withdrawn from the climate fund over the forecast period.

The Government’s case

The Department of Finance presents the funds as the core of a cautious strategy. “Capitalising the Government’s two savings vehicles is integral to promoting intergenerational equity,” the Economic and Fiscal Outlook says.

Its tables show a headline surplus in every year to 2030. The Budget in Brief points to a €275.4 billion infrastructure commitment over ten years, describing it as “the largest ever capital investment plan in the history of the State.” On this view, volatile receipts are being turned into long-term assets: savings for later decades and capital investment now.

The Department does not hide the concentration risk. It is the source of the “three large multinationals” finding and of the underlying deficit figures in the table above.

The Fiscal Council’s case

The Irish Fiscal Advisory Council, the State’s independent budget watchdog, reads the same numbers differently.

In its flash release on Budget 2027, published on 6 October 2026, it recalls that “a sustainable speed limit of 5% for both was set in 2021”, referring to spending growth and tax changes. It says governments have budgeted for about 6 per cent a year and delivered about 10 per cent on average.

Its pre-budget statement in August found that net spending rose by 9.3 per cent in 2025, “above its 5.1% ceiling”.

On corporation tax, the Council says the Government “plans to spend about six-in-seven euros of all corporation tax revenues it takes in.” Excluding excess corporation tax, it puts the deficit “rising from €12 billion in 2026 to €20 billion in 2030”. That 2030 figure matches the Department’s own underlying projection.

It also argues that “the Government will effectively have to borrow to put money into its long-term savings funds for ageing costs from next year.”

Its recommendation is short: “The Government should be saving more, making its tax base more secure, and avoiding aimless drift.”

The two institutions are largely working from the same figures. The Council’s August estimate of potentially transitory corporation tax for 2027, €21.3 billion, is close to the Department’s €22.9 billion. The disagreement is about what to do with the money, and how fast spending should grow while it lasts.

What to watch

Monthly Exchequer returns. The Department of Finance’s October figures are next. They will show whether the delayed Pillar II payments begin to arrive, and whether the €34.1 billion forecast for 2026 holds.

The Fiscal Council’s Fiscal Assessment Report, due in November 2026. The flash release was the Council’s first reading of Budget 2027; the full report will set out its formal assessment.

Revenue’s next corporation tax report. The 2026 edition appeared on 7 May 2026. The next one will cover 2026 payments, the first year in which the new minimum tax is payable, and will update the top 10 share.

Pillar Two receipts. Revenue says the Domestic Minimum Top-Up Tax becomes payable from June 2026 and is “expected to increase ETRs”, or effective tax rates, for groups in scope. How much of the 2027 forecast it accounts for, and how permanent that money proves, will shape the next round of windfall estimates.