17th September 2021

Chambers Ireland pre-budget 2022 submission

Chambers Ireland has published its pre-budget 2022 submission. The submission is aligned to five of the United Nations SDG goals, adopted as part of  Chambers Ireland ethos, namely goals: 5, 8, 9, 11 and 13.

To read the full submission, click on this link:



Overview of pre-budget 2022 submission

A Strategy for Towns and Cities/Urban Ireland

Resource the Government’s Town Centre First Initiative for urban spaces so that
it focuses on the development of economically, socially and actively healthy
streets in our cities and towns.

Expand the Living City Initiative (LCI) to include long term vacant commercial
properties built post-1915 in the cities and towns specified in the NPF and
reformed to include acquisition costs of LCI qualifying properties.

Remove regulatory disincentives by amending the initiative and encouraging new
investment in these areas by incorporating the costs of buying LCI qualifying
properties into the relief and reducing the inheritance/CGT tax disincentives to
invest in certain properties by allowing the unused capital allowances attached to
a property to be transferred with ownership.

Introduce a targeted, time-bound, reduction of construction VAT for affordable
high-density apartment new builds in cities.

Introduce a legislative framework that supports shared property ownership
models, like the co-operative and co-housing legal structures seen in the
Netherlands and Denmark, that will respond positively to the distinct challenges
of high-density urban living.

Town Centre First Initiative

Enact legislation to empower and resource local authorities as one-stop shops to
streamline the regulatory regime for change-of-use construction projects and
above-the-shop conversions

Extend Statutory Instrument 30 on change of use of commercial premises to
residential premises beyond 2021, and consider reforming the Statutory
Instrument so that the two-year waiting period is removed

Reform the Fair Deal Scheme so that when rental income accrues from a Fair Deal dwelling, the costs associated with renting that dwelling are discounted from
reckonable income. Up to 80% of the income which an individual on the Fair Deal
Scheme receives must go to the HSE, yet the share that remains is often less than
would be required to finance the investment, repair work, LPT, retrofitting, and
maintenance of a rented residential unit. This creates the perverse disincentive
that it can be cheaper to let a house lie empty than to have a tenant.

Reduce Vacancies
Sustainable Cities and Communities (SDG Goal 11)
Renew the Derelict Sites Act 1990 to strengthen its elements to incentivise infill
and brownfield construction.
Better resource local authorities to initiate street improvement and active travel
Introduce new legislation to expand and strengthen the powers of local
authorities to compulsory purchase vacant sites.
Modernise the land registry to facilitate the creation of a national vacant land
Implement a strengthened and centralised vacant land levy which acts as a charge
on the land regardless of the ownership with revenue being returned to the
relevant local authority.
Having reviewed the vacancy rates, the Department of Housing, Local
Government and Heritage should set vacancy reduction targets for local
authorities at the electoral district level.
Substantially increase the capital spend for housing in urban areas identified by
the NPF.

Councils that run large budget surpluses should be encouraged to invest the
excess in the local economy through Transport Orientated Development
Direct Local Authorities to integrate decisions on property taxes into the general
budget process, rather than the status quo where it is dealt with as a stand-alone
Invest in the urban built environment to provide social and community spaces and
resources, akin to those in rural areas.
Ensure that Local Area Plans require the inclusion of people-friendly pedestrian
infrastructure, segregated cycleways, and rest spots. This infrastructure is needed
to support active transit while linking residential areas with civic and economic
Provide funding to reform the planning system to ensure efficient decision
making, in combination with the upskilling of local authority planning departments
to allow for consistent and integrated decision making across the regions.
Implement training programmes for councillors to help them align Local Economic
and Community Plans and Local Area Plans with the European Green Deal to
enable increased access to EU funding.
Strengthen and resource the planning professionals in local authorities and other
relevant State agencies.

Support Urbanism
Create guidelines on how Local Authorities apply construction duties and levies to
ensure consistency across regions. The rebates of levies and charges should also
be used to ensure the completion of high-density developments
Introduce targeted reductions in construction duties and levies for developments
which are coherent with the NPF.
Improve information provided in the Commercial and Residential Property Price
registers to facilitate proper assessment of costs per square metre
Ensure regulatory certainty around high-density apartment planning
Amend EPA waste licensing rules to facilitate on-site reuse

Support Efficiency in Construction Costs
The Government must commit to the principles and objectives of the NPF and
integrate it with the Climate Action Plan, applying the revised European
Commission definitions of green investment.
Ensure that Transport Orientated Development principles form the core of all
new developments – the MetroLink Project offers a great opportunity develop
expertise in this area.
Prioritise traffic reduction measures in all our towns and cities while expanding
local active travel and public transport options.

Develop a National Active Land Management policy
Finalise and enact the legislative framework for the Land Development Agency,
granting it compulsory purchase and active land management powers in line with
the Kenny report, supporting this with a referendum if necessary
Building upon the National Planning Framework and the Climate Action Plan,
there needs to be co-ordinated efforts at regional level to integrate development,
land management and investment in public transport
Expand the mandate of Home Building Finance Ireland to provide low-interest
finance to fund construction projects on brownfield sites in town and city centres
Housing Policy
Delivering on
Climate Action
and Sustainable
Scale up the resources and skills in planning departments at local and national
levels so that better planning decisions can be made at earlier stages which can
survive scrutiny in the courts.
Ensure that An Bord Pleanála and the National Parks and Wildlife Service is
appropriately resourced to match the scale of our ambitions.
Invest in the courts and judicial system so that it can speedily adjudicate on any
planning decisions that come before it.
Deliver on the Programme for Government commitment to introduce an
Environmental and Planning Court which can fast-track hearings related to key
infrastructure projects and efficiently adjudicate on the merits of the cases before
Streamline the planning regime to reduce uncertainty for key infrastructure
Make greater use of the Regional Assemblies and their ability to create strategic
master plans by increasing their internal resources to allow them to offer high-skilled expert planning services to local authorities, and to guide the integration of Local Area Plans with regional and national infrastructure.

Making the Planning System More Effective
With increased pressure on public finances it is important that we maintain the
‘Rainy Day Fund’ with the transfer of above profile corporate tax receipts and
other sources of windfall returns to the exchequer to ensure that they can be
used for funding capital infrastructure rather than current expenditure
Draft a roadmap on future taxation policy, detailing how Government intends to
transition/replace revenue from VRT/excise/motor tax

Optimise investment in capital projects and infrastructure by ensuring
transparency and an open approach to infrastructure funding models such as PPP,
to ensure progress is maintained

Improve the reporting requirements for all large projects and programmes

Prioritise infrastructure which aligns with the National Planning Framework, multimodal, and transport orientated development principles

Ensure that all critical infrastructure investment is aligned with the European
Commission’s ‘Sustainable Finance’ definitions

Finance Infrastructure Sustainably
Delivering on Climate
Action and Sustainable


Industry, Innovation and Infrastructure (SDG Goal 9)
Develop inter-urban and intra-urban public transport networks, and invest in the
urban built environment to promote local active transport networks that extend
the utility of public transport.

  • Invest in shared cycling schemes and cycling infrastructure
  • Urgently commence work on advancing the MetroLink
  • Prioritise intercity rail transport infrastructure
  • Progress the Dublin rail interconnector and Luas extensions
  • Fast-track the Cork Suburban Rail project
  • Implement BusConnects projects in all NDP growth cities

On existing rail routes, progress research into introducing high-speed sections to
reduce the conflict between intercity and commuter services.

Initiate feasibility studies, and cost benefit analyses – including carbon accounting
– on upgrading the links between the National Development Plan growth cities
through the rail network.
Accelerate the Dart extension projects and establish a timeline towards
developing an all-electric rail network.
Extend train lines, where suitable, to integrate freight to our trading seaports
Improve Transport Services.
Upgrade our electricity network to provide for long-term energy security by
increasing investment in the electricity grid.
Provide additional resources to connect renewable supplies to the network
Rapid rollout of legislation that will facilitate offshore wind farms.
Invest in the accelerated rollout of a national fast-charging network for the EVs
with a focus on regional areas, while providing for public transport in urban

Future proof the National Gas Grid by investing in biomethane technologies and
systems to provide renewable methane and hydrogen supply.
Ensure there is additional investment for water infrastructure, providing powers
to State bodies to finance such investment through land value capture
Securing National Energy Grid Infrastructure.
Move away from the Public Works’ standard form contract towards international
best practice alternatives.
The speedy implementation of a high-speed broadband throughout the country
must be prioritised as a key national economic concern.

Fund a civilian cybersecurity agency with a multiple mandate to:
Identify threats to ordinary residents in Ireland, state bodies, and businesses
Have a remit for penetration testing state bodies
Inform the public and train the business community on how to minimise the
risk to them and their property that arise from cybersecurity threats
We need to see common sense, risk-reducing, and reliable regulation in the area
of digital economy that will both protect innovation over the long-term and
withstand the scrutiny that is arising from the data of other nations’ citizens that
is processed in Ireland.

The Digital Economy
Commit increased investment in the electricity grid to ensure that it is futureproofed and has the capacity to meet decarbonisation targets, including the
progression of the North-South Interconnector and the Celtic Interconnector to
ensure energy security
Increase R&D spend and target funding to support research into how the gas
networks can be future proofed to transition from the delivery of natural gas to
renewable gas and the potential of hydrogen as a means of storing excess
Strategic investment must be directed into one or more Irish ports for the
construction of offshore wind farms to take maximum advantage of the
Programme for Government’s commitment to delivering 5GW of offshore wind by

Generating Renewable Energy
Climate Action (Goal 13)
Ring-fence all Exchequer returns from Carbon Tax and strategically invest in green
infrastructure, public transport, and funds that will support communities to
transition to green transport and heating alternatives
Publish a schedule of increases in Carbon Tax between 2021 and 2030, so that
businesses have greater certainty on expected costs.

Decarbonising Heat and Transport
Following any phased increases to the Carbon Tax, Government must commit to
carrying out impact assessments on the consequences for SMEs, commuters and
border communities.
Increase investment in the decarbonisation of public transport, particularly in
cities, such as investment in bio-methane vehicles and the electrification of trains
and buses. Road usage plans must also prioritise public transport.
Invest in appropriate infrastructure to support the transition of Heavy Goods
Vehicles to low-carbon fuel options like Compressed Natural Gas.
Invest in an accelerated roll-out of a national fast-charging network for Electric
Vehicles, particularly in rural parts of the country where there are limited options
for public transport.
Use ring-fenced environmental fund revenues to broaden the coverage and
density of shared use schemes (such as City Bikes) in the cities where they are
available and expand them to other towns where they are not yet provided,
enabling social distancing requirements to be more easily met.
Commit funding to expand the network of local authority energy agencies to act
as a local one-stop-shop structure providing practical advice to households and
businesses on significantly reducing carbon emissions, retrofitting homes and
availing of Government supports and advice from agencies like the SEAI or theClimate Action Regional Office.
Classify SEAI supported retrofitting projects as zero VAT rated products
Ensure that funding and resources are allocated to research innovative
technologies such as Carbon Capture Storage, Hydrogen, Biogas and Anaerobic
Invest in re-training programmes to support the transition from jobs reliant on
fossil fuels to low carbon jobs in areas such as energy retrofitting for buildings,
sustainable forestry, renewable energy and peatland restoration, to name a few
Continue to invest in measures that will support communities to meet
afforestation and bog restoration targets.
Ongoing investment in water infrastructure to ensure the sustainability of
supplies into the future and ensuring we safeguard our environment through the
elimination of the discharge of untreated water into our rivers and seas
Accelerating the Transition to the Circular and Low Carbon Economy

Inclusive and Productive Local Economies
Extension of the Small Benefits Exemption to allow employers to give a voucher
in 2021 up to the value of €1,000, which can be drawn down in two parts, on a
tax-free basis, and will stimulate retail spend in local economies.
Reform the “Stay and Spend” tax credit for the tourism and hospitality sector and
immediately replace it with a form of local voucher for all adults that can be spent
on tourism and hospitality for a defined period of time, targeted at the ‘shoulder
Extend the reduced VAT rate for hospitality & tourism businesses until the end of
Ensure adequate staffing resources are afforded to local authorities to enable the
effective and speedy implementation of out-door dining and public realm grants,
that support dwell time and healthy streets within our town and city centres.

Ensure the ‘Think Small First Principle’ is applied to all grant applications to
support SMEs.

Publish a national aviation strategy that will target and allocate multi-annual
funding for CapEx, OpEx and marking expenditure. These supports for airports
will help those vulnerable to the impacts of the pandemic to retain existing routes
and develop new routes further afield, which will subsequently support growth of
tourism and economies in these regions as part of the post-Covid-19 recovery.

Resource state agencies to increase levels of investment in niche areas that
distinguish Ireland as a destination, such as Ireland’s growing potential as a place
for unique and high-quality food and active tourism.

Stimulus for Local Economies
Extension to the waiver on commercial rates for impacted businesses to the end
of 2021 with the shortfall in funding to be refunded to local authorities by central
Government. This extension should be paired with more accessible criteria to
enable the speedy processing of applications
Reintroduction of a Redundancy Rebate Scheme for sole traders and SMEs for a
defined period of time.

Sustained Financial Support for Vulnerable Sectors
Decent Work and Economic Growth (SDG Goal 8)

Reform the Employment Investment Incentive Scheme (EIIS) through the
following measures:

  • reduction of administration and simplification qualifying criteria
  • make more attractive to investors
  • prioritise flexibility
  • improve investor participation

Reduce the Capital Gains Tax rate of 33% for non-passive investment in order to
promote more all-island alignment on this kind of tax policy. This move will also
help the exchequer to benefit from taxation dividends that arise from CGT as
individuals will have less incentive to engage in regulatory arbitrage though
availing of foreign taxation regimes.
Increase the lifetime limit of €1 million in qualifying capital gains under
Entrepreneur’s Relief to improve the attractiveness for repeat investors and to
encourage increased investment in Irish business.
Expand and simplify eligibility criteria for the R&D tax credit rate to medium sized
Review and simplify the reliefs which are available, such as Retirement Relief, and
integrate it within a more expansive Entrepreneurs’ Relief
Introduce a mechanism where entrepreneurs can apply for a “small business
rollover”, which would support serial entrepreneurship.
Improve conditions to enable greater access to financial, venture capital and
private equity markets to grow.
Conduct further review and reform of the Key Employee Engagement Programme
(KEEP) to ensure that it continues to be accessible and user-friendly

Supporting Entrepreneurs and SMEs
Commit to maintaining Ireland’s 12.5% rate of Corporation Tax.
Lead, resource and implement an Action Plan for Trade, which is target driven,
and aims to increase SME engagement with international trade, both within and
outside the EU. This will support SMEs to be more productive and will also help
SME traders to adapt to the UK being outside the EU.
Introduce additional supports for businesses, including retail, who wish to expand
their activities in e-commerce with a view to becoming more engaged in the
Digital Single Market and with a view to competing with UK businesses selling
online, who may have a competitive edge post Brexit, due to exchange rate

Trade and Investment
Review and reform the existing e-working allowance to support workers and
employers who are continuing to engage in remote working.
Increase the individual tax rebate for working from home, which can currently be
claimed against 10% of the costs of home working (e.g. electricity, broadband,
Increase resources, both in staff and funding, to the Regional Skills Fora, in line
with population, to support their efforts to address skills needs around the
Allocate funding to deliver disability awareness training for organisations
Fund a workplace access programme to support labour participation for people
with disabilities.
Amalgamate all current supports in the Reasonable Accommodation Fund banner
into one overall grant and guarantee that funding for specialised equipment is
received and controlled by the employee.
Reform the Reasonable Accommodation Fund so that the supports are fit for
purpose in a modern workplace.

Provide flexible and inclusive workplaces

Gender Equality (SDG Goal 5)
Increase investment in childcare services, early education infrastructure and
schools that are reopening to facilitate breakfast clubs and after school childcare
in all parts of the country to help working parents and mitigate against the
reduction in supply of childcare places that has arisen from Covid-19
Expand mentoring programmes like “Better Start” that aim to improve the quality
of childcare and early childhood education.
Ensure continued investment in the Early Childhood Care and Education (ECCE)
Increased investment in services and infrastructure that enable childcare
providers to expand places for children under the age of three
Access to Affordable Quality Childcare.
The CSO reported that almost half (45%) of fathers entitled to paternity benefit
did not take it in 2018. Budget 2022 must set aside funding to enable a review of
Paternity Benefit to better understand any obstacles for take-up to support
parenting equality.
Conduct a review of parental leave supports (maternity, paternity and parental
leave) that the state provides over the course of an individual childhood, to better
understand any obstacles to take-up and barriers to greater parenting equality
Supports for Parental Equality.

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