On 9 May 2025, the National Treasury Management Agency completed the transfer to the Irish Exchequer of fourteen point two five billion euros recovered from Apple under the European Court of Justice's September 2024 ruling. Four days later, on 13 May 2025, the escrow account that had held the money for nine years was formally closed. The funds are earmarked, alongside the proceeds of recent bank share sales, for a twenty-three percent increase in the National Development Plan running through 2030, primarily for electricity, water, housing and transport infrastructure. The Minister for Finance, Jack Chambers, in his statement on the ECJ ruling, described the issue as now of historical relevance only. It is not. Apple's Irish profit-shifting was the case study that opened Gabriel Zucman's first major book ten years before the ECJ ruled, and the structural argument it illustrates is the first installment of a longer argument the Irish state has so far refused to engage.

This piece is the second of a pair. The first, What the Finance Minister Already Knew, set out the long arc of wealth concentration documented by Thomas Piketty, where Ireland sits on it and the question of whether the political realignment Piketty's framework predicts is now arriving in Irish electoral behaviour. This piece deals with the operational mechanism: what would actually need to happen for Ireland to do anything serious about the concentration the first piece named. The answer the rest of this argument will defend is that Ireland is uniquely placed, in 2026, to be the first European country to legislate a Zucman-shaped minimum effective tax on the wealth of its richest individuals. Uniquely placed because of facts about the Irish state that are usually treated as embarrassments, including the structure of its corporation tax base, its small legislative footprint, its operational experience implementing exactly the same kind of minimum-tax mechanism in a different domain and the precedent of having legislated and then abolished a wealth tax fifty years ago.

Who Zucman is

Gabriel Zucman completed his PhD at the Paris School of Economics in 2013 under Piketty's supervision. He is currently Professor at the Paris School of Economics and at the École Normale Supérieure, founding Director of the EU Tax Observatory hosted at PSE and Associate Professor at the University of California, Berkeley. In 2023 he received the John Bates Clark Medal, awarded by the American Economic Association to the economist under forty judged to have made the most significant contribution to the field. The Clark Medal is a serious-economics judgement, not a political one.

Zucman's first major book, The Hidden Wealth of Nations, was published in French in 2013 and in English with a foreword by Piketty in 2015. Its principal empirical finding was that approximately eight percent of global household financial wealth, around seven point six trillion dollars, is held offshore, with three-quarters of that figure undeclared to the tax authorities of the residents who own it. The book includes a chapter on the structural role of multinational corporate profit-shifting in the global tax system, and the principal case study in that chapter is Apple's Irish operations. The architecture Zucman described in 2015 is the architecture that the European Commission challenged in its 2016 state-aid decision against Apple, that the European Court of Justice upheld in its September 2024 ruling and that Ireland was required to recover from in cash terms in May 2025.

His second book, The Triumph of Injustice, written with Emmanuel Saez and published in 2019, supplied the empirical finding that in the United States, for the first time in over a century, billionaires now pay a lower effective tax rate than their secretaries. The methodology was the same as Piketty's: long-run consistent series, primary data, transparent assumptions. The conclusion was contested by some Republican-aligned commentators. It has not been contested in the peer-reviewed literature.

The 2024 EU Tax Observatory Global Tax Evasion Report, the report whose findings Piketty was responding to with the extra-month-of-income comment quoted in the first piece, made a similarly direct empirical claim. Irish-based firms paid an effective corporate tax rate of approximately seven percent in 2020, well below the headline statutory rate of twelve point five percent. Globally, roughly one trillion dollars of corporate profits were shifted to low-tax jurisdictions in 2022, with Ireland and the Netherlands the two largest destinations.

None of this is contested in the way political commentators often imply. The substantive disagreement is not about the data. It is about whether the data should be acted on.

The Zucman minimum tax, the actual design

In February 2024, the Brazilian government, in its capacity as G20 president for the year, invited Zucman to address G20 finance ministers in São Paulo on the structural failure of the current international tax system to effectively tax the wealth of ultra-high-net-worth individuals. In the months that followed, Zucman produced a full report at the Brazilian presidency's request. The report, A Blueprint for a Coordinated Minimum Effective Taxation Standard for Ultra-High-Net-Worth Individuals, was published on 25 June 2024, ahead of the G20 finance ministers' meeting in Rio de Janeiro the following month.

The proposed design is a minimum effective tax of two percent of wealth per year, applied to individuals worth more than one billion dollars. Approximately three thousand people globally. The headline revenue estimate, assuming near-universal compliance from a coordinated standard, is two hundred to two hundred and fifty billion dollars per year. The G20 communiqué noted that an extension of the threshold downward, to one hundred million dollars or euros, was supported by sixty-nine percent of polled millionaires themselves and would add a further one hundred to one hundred and forty billion dollars per year in revenue.

Two features of the design matter most. The first is that it is a minimum, not a new tax. The mechanism is to ensure that whatever combination of existing income, capital gains, dividend and corporate taxes the affected individual already pays, the total amount adds up to at least two percent of net wealth per year. The point is to prevent the under-taxation pattern documented by Zucman and others, where the very wealthy report effectively zero income in any given year because their wealth grows through unrealised capital appreciation rather than through taxable salary or distributed dividends. The Jeff Bezos pattern, where the founder of one of the largest companies in the world reports almost no income to the tax authority because he draws no salary and instructs his company to distribute no dividends. The minimum-tax design closes this loophole by reference to the underlying wealth itself.

The second feature is that the rate is expressed as a percentage of wealth, not of income. This is unavoidable, given the first feature. If the minimum were expressed as a percentage of income, an individual whose income was zero by tax-code definition would owe zero minimum tax. The whole purpose is to ensure that the calculation rests on something the individual cannot reduce to zero by financial structuring, and net wealth, measured at year-end and based on actual asset holdings, is the closest available object.

The exit-tax design is the third pillar. Zucman's report addresses the most-cited objection to any wealth tax, that the wealthy will simply relocate to a non-implementing jurisdiction. The proposed answer: any country implementing the standard can include a tail provision, under which an individual who has been resident for some defined number of preceding years remains on the tax base for some defined number of years after relocation. The United States already does the strongest version of this for income tax, on the basis of citizenship rather than residence. Any country with a serious tax administration can do the residence-based version. The empirical evidence Zucman and his collaborators have assembled on actual migration flows in response to wealth taxes is that the flows are real but smaller than the public-debate framing implies. The exit-tax design narrows them further by removing the immediate fiscal incentive to relocate.

The G20 communiqué, issued on 26 July 2024 at the conclusion of the Rio finance ministers' meeting, stopped short of agreeing the specific standard. It included language committing G20 members to engage cooperatively to ensure that ultra-high-net-worth individuals are effectively taxed, with full respect to tax sovereignty. France, Spain, South Africa and Brazil were the principal supporters. The United States, under Treasury Secretary Janet Yellen, and Germany resisted formal commitment. This was the picture in summer 2024. It has shifted significantly since, in ways the closing sections of this piece will return to.

Ireland already implements a Zucman-shaped tax. On multinationals.

The Finance (No. 2) Act 2023, signed into law on 18 December 2023, transposed Council Directive (EU) 2022/2523 into Irish law. The directive is the European Union's implementation of the OECD's Pillar Two minimum corporate tax framework, agreed by approximately one hundred and forty countries through the OECD Inclusive Framework process between 2021 and 2023. The Irish Act applies to multinational enterprise groups with consolidated annual turnover above seven hundred and fifty million euros. The mechanism consists of three components: an Income Inclusion Rule, an Undertaxed Profits Rule and a Qualified Domestic Minimum Top-up Tax, each set at fifteen percent effective rate. First filings under the legislation are due in June 2026.

Minister Donohoe's Budget 2026 statement, delivered in October 2025, acknowledged considerable uncertainty around the international Pillar Two framework but did not publish a specific yield estimate. Independent analysis is more forthcoming. The Irish Fiscal Advisory Council's Working Paper 25, by Brian Cronin and published in April 2025 under the title More Revenue and More Concentration, found that had the 15% Pillar Two minimum effective rate been in place from 2018 to 2022, Irish corporation tax revenues would have been on average eighteen percent higher over the period. The paper's headline second finding is that virtually all of this additional revenue would be excess, in the sense that it cannot be explained by underlying domestic activity, and is therefore subject to the same concentration risks the existing receipts already carry. The yield is large in absolute terms, even by the standards of an exchequer already running at structural surplus.

The structural significance of Pillar Two for the purposes of this piece is not the revenue. It is the demonstration that the principle of a minimum effective tax, on entities best placed to evade ordinary taxation, calibrated to a single rate expressed as a percentage of an underlying value the entity cannot reduce to zero through financial structuring, is operationally implementable. The Irish state has legislated such a tax. The Revenue Commissioners are operationalising it. The first cash receipts will arrive in 2026. The principle is no longer hypothetical.

The contrast with the discussion of individual wealth taxation is the operative point. The same structural argument, applied to individuals, is treated in Irish political discourse as unthinkable, technically dubious and constitutionally suspect. None of these characterisations holds against the working operational example just down the street. The multinationals are taxed at a fifteen percent minimum effective rate on profits attributable to Irish operations, with exit-prevention built into the rules through the Income Inclusion Rule and Undertaxed Profits Rule's extra-territorial reach. The same logic, applied to net wealth of individuals above one hundred million euros at a two percent minimum effective rate, is the Zucman design.

The same logic on individuals is treated as unthinkable

What follows is the current set of Irish party positions on wealth taxation, drawn from the most recent Alternative Budgets and stated manifesto positions of the major parties as of late 2025 and early 2026.

Sinn Féin's Alternative Budget 2026, published in October 2025 under the title Ending the Rip-off, set out a thirteen point four billion euro package. The party formally dropped the specific wealth-tax proposal it had carried since the early 2010s, of one percent annual tax on individual net wealth above one million euros. The replacement position is the establishment of a Wealth Tax Commission, to be set up in government to design the regime, rather than a specific design to be legislated immediately. Active distributional measures in the package include a three percent solidarity tax on individual income above one hundred thousand euros, increases in deposit interest retention tax and capital gains tax targeting Irish Real Estate Investment Funds and Real Estate Investment Trusts, abolition of the Universal Social Charge on the first forty thousand euros of income and a tripled bank levy.

The Social Democrats' Alternative Budget 2026, also published in October 2025, includes a super-wealth tax projected to raise two hundred million euros within an overall tax-rise package of three point four five billion. The older Social Democrats positioning has talked in terms of half a percent on individual assets above one million euros, or one percent on assets above two million euros. The current Alternative Budget formulation is sharper at the top and narrower in scope.

Labour's position, articulated in January 2026 by finance spokesperson Ged Nash, calls for the immediate introduction of a targeted net wealth tax modelled on the Spanish system, projected to raise four hundred million euros in net revenue. Labour's published position is that the tax should be modest in rate and recurring in design, with few exemptions and clear application to land as well as to financial assets, with exit-tax provisions attached.

People Before Profit's Alternative Budget 2026, branded Make the Rich Pay, proposed a nine billion euro wealth tax on multi-millionaires as part of a larger sixty billion euro revenue-raising package.

The Green Party's 2024 general election manifesto did not include a wealth-tax proposal. Tax policy in the Greens' published programme is focused on band and credit reforms, transport, housing and climate.

Fine Gael and Fianna Fáil have consistently opposed wealth-tax proposals when in office. The most-cited recent ministerial intervention is from then-Tánaiste Leo Varadkar in September 2022, who dismissed the wealth-tax-shift recommendations of the Commission on Taxation and Welfare as straight out of the Sinn Féin manifesto. The Commission had been appointed by his own Minister for Finance, then Donohoe. Fintan O'Toole's response in The Irish Times the same week characterised the Varadkar intervention as a disgraceful effort to stifle debate on a question the Commission had been asked to examine and had answered.

The honest reading of this distribution: there is no Irish party currently in or seeking government office with a Zucman-shaped proposal on the books. The redistributive parties have wealth-tax proposals of varying ambition, none designed as a minimum effective tax expressed as a percentage of net wealth on the very richest individuals. The conservative parties oppose the principle. The repositioning currently visible at Sinn Féin's strategic level, with the specific one-percent-above-one-million proposal replaced by a Wealth Tax Commission promise, takes that party further from the Zucman design rather than closer to it.

The Dublin Central by-election result reported in the first piece is structurally relevant here. A party caught between an anti-establishment right that is strengthening and a soft left whose distributional offer is more credible than the party's own current position is structurally pushed off hard distributional commitments. Each of the segments of the party's base reads the same wealth-tax proposal differently, and the path of least internal conflict is to soften the proposal. Sinn Féin's move from one percent above one million to a Wealth Tax Commission is a textbook instance. This is one of the ways the Brahmin Left configuration arrives in a country whose previous redistributive vehicle was a working-class nationalist party. The party that was the credible wealth-tax voice in the early 2010s is now less so, and the slack is being picked up by smaller soft-left parties whose Alternative Budgets are sharper but whose seat counts cannot yet legislate.

Not just refusing the floor. Building the ceiling.

The clearest current Irish government policy statement on the direction of travel on individual capital taxation is not the absence of a wealth tax. It is the active proposal, announced by Tánaiste and Minister for Finance Simon Harris in March 2026, of a Swedish-style Investment Savings Account modelled on Sweden's Investeringssparkonto. Under the proposed design, capital gains tax on returns inside the wrapper would be replaced by a flat annual levy on the total fund value. There would be no tax on individual trades, no capital gains tax on realised returns inside the wrapper, no entry or exit tax and a tax-free allowance at the lower end of the account size distribution. The pitch, in Harris's own framing, is empowerment of middle Ireland to invest in a way that is convenient. The first Annual Savings and Investment Forum convened in early 2026, bringing together what the Department of Finance described as the key industry and policy stakeholders. The legislative framework is targeted for 2026 with accounts available from 2027. The Social Democrats' immediate public response to the proposal, reported in The Journal in March 2026, was to call it a tax break for millionaires.

The structural symmetry is the operative point. Ireland legislated a one percent annual levy on individual net wealth above one hundred thousand pounds in 1975. The mechanism was a tax that bit on accumulated wealth. The current government is proposing a one percent annual levy on the total value of an investment account under the Investment Savings Account model. The mechanism is a tax whose actual function is to exempt the growth of wealth held inside the wrapper from the capital gains tax that would otherwise apply.

Same rate. Same mechanism. Opposite direction. The 1975 tax took from wealth-holders. The 2026 proposal exempts wealth-holders' returns from a tax that already exists. Stated bluntly: in the same six-month window in which France's National Assembly was being asked to put a two percent minimum effective tax on individuals worth more than one hundred million euros, the Irish government was developing a one percent annual wrapper-fee on investment accounts in exchange for capital gains tax exemption on returns. Same direction, mirror image, two different countries.

The framing Harris used for the proposal, that one hundred and seventy billion euros is currently held by Irish households in deposit accounts and is therefore evidence of an investment gap, misreads what the deposit holdings actually show. The Central Bank's analysis of household deposit composition makes the picture clear: the deposits are highly concentrated. The households at the top of the deposit distribution have substantial deposits because they have substantial accumulated wealth. The households at the bottom have effectively nothing, because their wage income is fully absorbed by rent and the cost of existing in the Irish housing market. The twenty-three-year-old paying twelve hundred euros a month for a room in a shared house in Dublin does not have an investment problem. The household with two hundred thousand euros in a deposit account does. The Investment Savings Account proposal does nothing for the first household. It does a substantial amount, in present-value terms, for the second.

This is the configuration the Piketty framework predicts in the Brahmin Left / Merchant Right configuration. The propertied right's policy output, when challenged by the rising distributional demand from the soft-left realignment, is to make life materially better for the already-propertied, on the grounds that the already-propertied are the responsible savers whose long-term-investment behaviour the country needs to encourage. The argument is internally coherent within its own frame. The frame is the frame the realignment is now arriving to displace. The companion piece The Ladder They Pulled Up, published earlier in this arc, dealt with the wider configuration the Harris proposal sits inside: the simultaneous announcement of professionalised landlordism, youth-hiring decline and the tax shelter for the already-capitalised, all in the same week. This piece names what that configuration is, structurally, in the language of the political-economy framework.

We have done this before. In 1975.

The Wealth Tax Act 1975 was introduced by the Liam Cosgrave Fine Gael and Labour coalition government, with Richie Ryan as Minister for Finance. The Act applied a one percent annual charge on the net market value of taxable wealth held by individuals, discretionary trusts and private non-trading companies. The threshold was one hundred thousand pounds, which rose over the Act's short life through indexation and reliefs. Numerous exemptions were built in, including the principal private residence up to a cap, productive business assets and certain pension and insurance assets.

The yield was small. The 1985 Sandford and Morrissey study, conducted by Cedric Sandford and published by the Economic and Social Research Institute, found administration costs at approximately five percent of yield and compliance costs averaging eighteen and a half percent of the tax liability, with a median of twenty-eight percent. In plain English, wealthy taxpayers spent close to a fifth of their tax bill again on professional advisers to minimise that bill. The yield peaked at six point five million pounds in 1976.

Jack Lynch's Fianna Fáil opposition fought the 1977 general election on an expansionary platform of large income-tax reductions, the abolition of rates on private homes and the abolition of the wealth tax. The platform was unusually generous in the European context of the period, and Lynch was elected with a substantial overall majority. The Wealth Tax Act was abolished by section 38 of the Finance Act 1978, effective from 1 April 1978.

The conventional lesson drawn from this episode in Irish political discourse is that the wealth tax did not work. This is the wrong lesson. The right lesson is the one Zucman draws from every European wealth-tax failure of the late twentieth century. The taxes were poorly designed, riddled with exemptions, technically easy to avoid through standard structuring, administered by tax authorities that had insufficient information-gathering infrastructure for the asset categories the taxes were supposed to cover and abolished by lobbying once a determined enough political coalition formed. The 1975 Act was lawful. It was never struck down on constitutional or other grounds. It was abolished politically. The current Irish state has materially more administrative capacity, information-gathering infrastructure and inter-jurisdictional cooperation than the 1975 Revenue Commissioners had. The technical objections from 1978 do not transfer to 2026.

Diarmaid Ferriter has written on this episode at length, in The Irish Times and in Ambiguous Republic: Ireland in the 1970s published in 2012. His reading, which the historical record supports, is that the lobbying intensity from the small affected group disproportionately shaped the political outcome relative to the broader public support the tax retained at abolition.

What a Zucman-shaped Irish tax would look like

A Zucman-shaped Irish minimum effective tax on individual net wealth, designed to clear current political and legal bars, would look approximately as follows.

Threshold: one hundred million euros of net wealth, in line with the French legislative attempts and Zucman's own extension design. Application: the eleven dollar-billionaires resident in the Republic at the end of 2025, per Oxfam Ireland's January 2026 summary, plus any centimillionaire households the Revenue Commissioners identify through asset-registry cross-referencing with existing wealth-management disclosures. Rate: two percent minimum effective tax on net wealth, payable to the extent that ordinary income, capital gains, dividend and other taxes already paid by the individual in the year do not add up to that amount.

The Oxfam Ireland baseline of forty-six point three billion euros in combined wealth held by the eleven Irish billionaires gives a floor revenue figure of approximately nine hundred and twenty-six million euros per year before any centimillionaire extension. The centimillionaire population in Ireland has been estimated, on the basis of comparable European wealth-distribution work, at the low thousands. The additional revenue from a comprehensive centimillionaire band is plausibly an order of magnitude higher than the billionaire-only figure. Precision requires Revenue Commissioners modelling that has not yet been published.

Exit-tax provisions: any individual who has been resident in the Republic for the preceding ten years remains on the wealth-tax base for the subsequent five years after relocation, regardless of subsequent tax-residence claims in other jurisdictions. The mechanism is conceptually simple, administratively tractable for a country with Ireland's already-extensive double-taxation treaty network and an order of magnitude weaker than the United States citizenship-based system that the US already operates and that has not produced mass renunciations.

Constitutional considerations. Article 43 of Bunreacht na hÉireann recognises a natural right, antecedent to positive law, to the private ownership of external goods, and the State guarantees to pass no law attempting to abolish the right of private ownership. Article 43.2 qualifies the right by noting that its exercise ought to be regulated by the principles of social justice, and that the State may delimit its exercise by law in the interests of the common good. The leading Irish Supreme Court case on the limits of property regulation, Blake v Attorney General [1982] IR 117, struck down the Rent Restrictions Acts as an unjust attack on property rights, primarily because the legislation restricted the property rights of one group for the benefit of another without compensation and without regard to financial capacity. The reasoning bites against narrow, uncompensated, disproportionate restrictions on the rights of identifiable property-owners. It does not bite against broad-based progressive taxation of general application. The 1975 Wealth Tax Act was passed, applied and abolished politically. It was never struck down. No published Irish constitutional opinion has set out an argument that a properly-designed Zucman-shaped tax would fail Article 43. The conventional academic reading, articulated implicitly across the NERI, TASC and Social Justice Ireland output of the last decade, is that a properly-designed broad-based wealth tax with reasonable rates and clear social-justice purpose would survive the constitutional test. The 1975 precedent is the cleanest available empirical answer.

The yield from such a tax is meaningful but is not the whole point. The point of the design is not principally to raise revenue, although the revenue is real and addresses some real fiscal needs. The point is to enforce the principle of equality before the law on tax payment. The middle-class wage-earner pays a marginal income tax rate of forty percent above the standard cut-off, plus Universal Social Charge and Pay-Related Social Insurance, on every euro of wage income above the threshold. The billionaire whose wealth grows by ten percent in a year, with no realisation event, pays nothing. The Zucman tax floor closes that gap. The principle, not the revenue, is the central argument.

The international architecture has just collapsed

The closing months of 2024 and the calendar year 2025 saw the most rapid collapse of the international tax-cooperation architecture in the modern era. The relevant events, in sequence, were as follows.

On 20 January 2025, President Donald Trump signed an executive order on his first day in office declaring that the OECD Pillar Two agreement had no force or effect in the United States. The order directed the Secretary of the Treasury and the United States Ambassador to the OECD to notify the OECD that prior US commitments were void absent further Congressional action. It further directed an investigation into foreign tax rules deemed to be extraterritorial or disproportionately affecting US firms, with a sixty-day deadline for the Treasury to develop protective countermeasures.

In May 2025, the United States Congress introduced what became known publicly as the One Big Beautiful Bill Act. The bill included a provision designated as Section 899, characterised in commentary as a revenge-tax mechanism. The provision would have permitted the United States to raise its tax rates on US-source payments to persons resident in countries deemed to impose unfair foreign taxes on US firms. The definition of unfair foreign taxes was drafted broadly enough to include the Undertaxed Profits Rule of OECD Pillar Two, digital services taxes and diverted profits taxes. The bill was a direct retaliation mechanism against any country attempting to apply the international minimum tax to US-headquartered multinationals.

On 26 to 28 June 2025, the G7 capitulated. Treasury Secretary Scott Bessent announced an agreement with G7 partners under which Pillar Two would not be levied on US-headquartered groups in exchange for the United States withdrawing Section 899. The agreement was formalised as the side-by-side framework: the United States tax system would sit alongside Pillar Two rather than being incorporated into it, and US-parented multinational groups would be excluded from the Income Inclusion Rule and Undertaxed Profits Rule of Pillar Two in all participating jurisdictions, for both their domestic and their foreign profits. The Senate removed the proposed Section 899 from the One Big Beautiful Bill Act in response. The result is that the largest single source of multinational profit subject to under-taxation, the US-headquartered technology and finance sector, is now operationally excluded from the principal Pillar Two mechanisms designed to address that under-taxation.

As of late 2025, several dozen countries had publicly criticised the side-by-side approach. The framework remains in operational limbo. The Qualified Domestic Minimum Top-up Tax component of Pillar Two, which is the mechanism Ireland and over forty other countries have legislated, continues to apply to US-headquartered multinationals operating in those jurisdictions on the profits attributable to those operations. The Income Inclusion Rule and Undertaxed Profits Rule, which were the mechanisms by which one country could top up tax on under-taxed profits earned by a multinational in another jurisdiction, are operationally dead for US groups. The international architecture against multinational profit-shifting that ten years of OECD negotiation produced has been substantially gutted by six months of US unilateral action.

The relevance for the Zucman proposal on individuals is straightforward. The international-cooperation framing that closed Zucman's recent media engagements, in which one country would lead, demonstrate that the unilateral revenue is real and watch many other countries adopt the same design, was developed in the political conditions of 2023 and 2024. The 2025 collapse of the multinational architecture changes the calculation. The lead-by-example argument is now the only live route, because the cooperative-framework argument is now visibly broken. The good news, if the term can be used in this context, is that the Zucman tax on individuals is a purely domestic measure. It does not require international cooperation to be implemented. Any country can do it unilaterally. The exit-tax provisions in the design are the mechanism for closing the principal avoidance route. The US crackdown on international cooperation strengthens the case for unilateral national action on individual wealth, because the cooperative route on multinational profit is now visibly closed.

The broader reading: the events of 2025 are the structural confirmation of a dynamic that has been building for a generation. The political-economic configuration in which capital owners and their political representatives are operationally above the international tax-cooperation framework, in which their wealth is protected from collective oversight by the state apparatus they fund, in which any attempt at substantive distributional reform is met with the threat or the reality of retaliation through state mechanisms they directly or indirectly control, is the configuration the long-arc Piketty work documents. The Trump executive order is one expression of this. The September 2025 Arnault attack on Zucman as a pseudo-academic is another. The Harris Investment Savings Account proposal in Ireland is a third. These are not three different things. They are one structural dynamic, visible at three different scales, in 2025, in a way that makes the underlying configuration readable for a public audience for the first time in a generation. What is revealed when the architecture comes apart is what was always underneath it.

The mainstream-economics consensus the gatekeepers pretend does not exist

In July 2025, after the French Senate rejected the wealth-tax bill on 12 June, seven Nobel laureates in economics co-signed an op-ed in Le Monde calling on France to adopt the tax. The signatories were Daron Acemoglu and Simon Johnson, awarded the prize in 2024; Esther Duflo and Abhijit Banerjee, awarded in 2019; George Akerlof and Joseph Stiglitz, awarded in 2001; and Paul Krugman, awarded in 2008. The op-ed argued that ultra-wealthy individuals currently pay between zero and zero point six percent of their wealth in income tax, and that France had the opportunity to demonstrate the workable design to the rest of the world.

Olivier Blanchard, the former Chief Economist of the International Monetary Fund, signed onto a separate joint op-ed with Zucman supporting the design. Blanchard is one of the most-cited macroeconomists of the past thirty years and held the most senior macroeconomic-research position in the international financial architecture for a decade. He is not a person whose endorsement can be dismissed as fringe.

The argument that the proposed design is theoretical, untested, or held only by a small group of activist academics is empirically false. The mainstream of professional economics, judged by the publication record of the journals the discipline takes most seriously and by the awards the discipline itself confers, supports the principle. The disagreement is not within the discipline. It is between the discipline and the political class that draws on the discipline selectively.

The Irish question is whether the Irish political class, having read and understood the work, as Donohoe's 2020 Capital and Ideology review demonstrates, is prepared to act on the substance the discipline supports. The answer to that question, on the budgets of 2024, 2025 and 2026, has been no. The repositioning at Sinn Féin in late 2025 takes the party further from the Zucman design rather than closer. The active government proposal in the Investment Savings Account is structurally the opposite of the Zucman design. The substantive economics-policy direction of the Irish state is in the opposite direction to the substantive economics-policy consensus.

What Ireland is uniquely placed to do

Ireland in 2026 is, by accident more than by design, the country most operationally placed in Europe to be the first to legislate a Zucman-shaped minimum effective tax on individual wealth. The conditions for this claim are as follows.

First, the operational template already exists in Irish law and is being implemented by the Revenue Commissioners. The Finance (No. 2) Act 2023 transposed the same design pattern, expressed against the same kind of underlying object, with the same exit-prevention logic, against a category of taxable entity. The technical staff at Revenue who will be processing the first Pillar Two filings in June 2026 already understand the mechanism. Extending the principle to individuals does not require new conceptual infrastructure. It requires a separate Act applying the same design to the natural-persons base.

Second, the legislative footprint is small. The 1975 Wealth Tax Act was approximately twenty-five pages of statutory text. A modern Zucman-shaped minimum effective tax Act, with the necessary cross-references to the Income Tax Acts, the Capital Acquisitions Tax Acts and the Pillar Two provisions, would plausibly run to forty or fifty pages. The Department of Finance and the Office of the Parliamentary Counsel have drafted longer Acts on tighter timelines.

Third, the demographic-inheritance moment in Ireland is more acute than in any comparable European jurisdiction. Ireland has the youngest population in the European Union as a share of total. The under-thirty-five cohort is the largest in the bloc as a fraction of national population. The cohort holding the wealth, who are predominantly in their sixties and seventies and own the bulk of the residential property stock, will transmit that wealth to the next generation over the coming twenty years. The intergenerational transmission will determine whether the under-forty population can establish housing security at all. Without distributional reform on the wealth side, the transmission will sharply increase wealth concentration within the next generation, because only the heirs of the current property-owning cohort will be able to participate in the property market. With distributional reform on the wealth side, including a minimum effective tax of the kind discussed in this piece and a serious reform of the inheritance and capital acquisitions tax regime, the wealth concentration can be moderated and the housing market can begin to function for those without inherited wealth. The window for this reform to make a difference closes when the current property-owning cohort dies and the transmission is complete. It does not close in 2030 or 2040. It closes over the next two decades on a rolling basis.

Fourth, the Apple ruling has demonstrated, in the most cash-immediate possible way, that the international architecture for taxing internationally mobile profit can produce billions of euros for the Irish Exchequer when the courts hold their line. The fourteen point two five billion euros received from Apple in May 2025 is real, sitting in the National Development Plan increase, financing infrastructure investment over the next decade. The political-economy argument for the proposition that taxing concentrated wealth is technically impossible is empirically refuted by the cash that the same political class accepted from Apple under the ECJ ruling. The next step is the application of the same principle to the same kind of object, on the natural-persons base.

Fifth, the Irish political class has been visibly engaged with the substantive argument. Donohoe wrote the 2020 review. The Commission on Taxation and Welfare's 2022 recommendations included a substantive shift in the tax base toward wealth and property. The Irish Fiscal Advisory Council's recent publications include sustained analysis of corporation tax concentration and the need for a more diversified revenue base. The Irish Times editorial position of 19 January 2026, in response to the Oxfam findings on Irish billionaires, identified wealth concentration as the issue. The conversation exists. The substance is known. The remaining question is political will. The companion piece What the Surplus Hides set out the wider fiscal context: a Republic running structural surpluses on a dangerously concentrated corporation-tax base, with two sovereign wealth funds being built against the day the windfall closes, with the demographic and housing pressures the wealth-tax proposal would directly address. The wealth-tax-on-individuals piece this article makes the case for sits inside that fiscal context as the most-bite-per-page-of-legislation measure available to the next government.

Which design feature do you oppose, and why?

The companion piece to this pair, Every Reform, None Enacted, proposes a question to be put to every Irish politician at every election: which of the five named beats of the accountability programme do you oppose, and why. The structural analogue for this piece is the same question, in the same form, on the rules-of-capital programme this pair has set out.

Which of the following design features of a Zucman-shaped Irish minimum effective tax on individual wealth do you oppose, and why?

The threshold of one hundred million euros of net wealth. The threshold is high. It touches approximately the same individuals identified by the Oxfam January 2026 summary as the eleven Irish dollar-billionaires, plus a small number of additional centimillionaires.

The rate of two percent minimum effective tax. The rate is low. Two percent of net wealth is materially less than the marginal income tax rate of forty percent that any middle-class wage-earner pays on every euro of wage income above the standard cut-off.

The minimum-tax design, payable only to the extent that ordinary tax already paid does not reach the floor. The design is conservative. It does not double-tax income that the individual has already paid full tax on. It only catches the gap when reported taxable income has been structured down to zero or near-zero through legitimate but problematic means.

The exit-tax provision of a five-year tail after relocation for individuals resident for the preceding ten years. The provision is weaker than the United States citizenship-based tail that has been operational without major incident for decades.

The application to individuals at the level of net wealth used by the Revenue Commissioners for capital acquisitions tax purposes, with the same valuation methodology. The methodology is already in operation, applied annually, for inheritance-tax purposes.

A politician who cannot name a single one of these design features as something they specifically oppose has no substantive argument against the proposal. They have only the underlying preference that the very wealthy should not pay tax at a rate proportionate to the rest of the population. That preference, stated plainly, is not a position any Irish elected official is willing to defend in public. The refusal to defend it is not the same as an actual argument against the tax. The 1975 precedent is the empirical answer to most of the technical objections. The Pillar Two implementation is the empirical answer to the design-tractability objections. The seven-Nobel-laureate consensus is the answer to the mainstream-economics objection. The Donohoe 2020 review is the answer to the does-the-political-class-know-the-argument question.

What remains is choice. The political class has read the argument and has chosen the side that loses on the test. The substantive question, for any Irish voter, journalist, branch-level political organiser or campaigner, is which candidates at the next general election will be asked to commit, in public and in writing, to which of these five design features they oppose. The answers will sort the political class very quickly into those who can defend their position and those who can only refuse to take the question.

Which is, as the companion piece on the rules-of-office accountability programme puts it, the only useful question.

This piece is Part II of a pair. Part I, What the Finance Minister Already Knew, covers the long-arc Piketty diagnosis, the World Inequality Database Ireland series, the Brahmin Left / Merchant Right framework, the Dublin Central by-election as evidence of arrival and the line through to Zucman's reformulation of the wealth-tax proposal.

Source notes. Apple ECJ ruling: Case C-465/20 P, judgment of 10 September 2024. Apple Escrow Fund cover note: Department of Finance, 2024 financial statements, May 2025. Finance (No. 2) Act 2023: irishstatutebook.ie. Council Directive (EU) 2022/2523. Irish Fiscal Advisory Council, B. Cronin, "More Revenue and More Concentration: Ireland Corporation Tax Paper", April 2025; Fiscal Assessment Report November 2025. G. Zucman, A Blueprint for a Coordinated Minimum Effective Taxation Standard for Ultra-High-Net-Worth Individuals, report to the G20 Brazilian presidency, 25 June 2024. G. Zucman, The Hidden Wealth of Nations, University of Chicago Press, 2015. E. Saez and G. Zucman, The Triumph of Injustice, W.W. Norton, 2019. EU Tax Observatory, Global Tax Evasion Report 2024, October 2023. French wealth-tax bill: Assemblée Nationale records, 12 February 2025 tabling by Éva Sas (EELV), 20 February 2025 first-reading adoption 116-39, 12 June 2025 Senate rejection 188-129, 31 October 2025 second-round vote. Wealth Tax Act 1975: irishstatutebook.ie. Finance Act 1978 section 38: irishstatutebook.ie. C. Sandford and O. Morrissey, The Irish Wealth Tax: A Case Study in Economics and Politics, Economic and Social Research Institute, 1985. Sinn Féin Alternative Budget 2026, Social Democrats Alternative Budget 2026, Labour Alternative Budget 2026, People Before Profit Alternative Budget 2026, all October 2025. Trump executive order on the OECD Pillar Two: 20 January 2025. G7 side-by-side agreement: US Treasury press release, 26-28 June 2025. Le Monde op-ed by seven Nobel laureates: July 2025. Central Statistics Office, Household Finance and Consumption Survey 2023, published 11 June 2025. Oxfam Ireland, Resisting the Rule of the Rich, January 2026. Bunreacht na hÉireann Article 43; Blake v Attorney General [1982] IR 117.

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