What is the RZLT?
The RZLT imposes a 3% tax on the market value of certain residential land. The purpose of the tax is to encourage the development of residential zoned land to assist with the housing crisis.
Land in scope of the RZLT
RZLT applies to any land that is zoned for residential use, which is serviced, i.e. capable of being connected to the necessary public infrastructure, e.g. roads, footpaths, lighting, sewerage etc.
Prior to 31 January 2026, each local authority was required to publish a map outlining the lands that are zoned for residential purpose within its boundaries. Landowners should check their local authority map to determine whether their land is within the scope of RZLT. The maps are available to view online.
If land has been zoned incorrectly as residential on the 2026 revised maps, landowners have until 01 April 2026 to make a request to their local authority to change the zoning of the land.
Residential properties are excluded from the tax; however, it is important to note that there may be a requirement to register for RZLT where a residential property has a garden or yard larger than 1 acre.
Based on the 2025 maps, many landowners may be required to register for the RZLT but are unaware of this reporting obligation.
Filing your RZLT return and who is liable
RZLT is a self-assessed tax and the responsibility for filing and making payments rests with the owner of the land on 01 February 2026.
Where land falls within the scope of the RZLT on 1 January of a particular year, tax is charged in the third year after the year in which it comes within scope.
Where land was within scope on 01 January 2022, the first valuation date for RZLT was 01 February 2025. After that, the relevant site will be valued on 01 February every three years following the first valuation. Therefore, the RZLT liability for 2025, 2026 and 2027 will be based on 3% of the market value of the site on 01 February 2025.
If the land first falls within the scope of RZLT on 01 January 2026, the first valuation date for RZLT will be 01 February 2029.
Where an RZLT return is due to be filed, the deadline for filing the return is 23 May 2026.
RZLT is not a deductible expense for corporation tax, income tax or capital gains tax purposes.
Exclusions from the RZLT
There are several situations where lands may be excluded from the RZLT, including:
- Land liable to the Derelict Sites Levy.
- Land zoned for residential use, which is used by a trade or business liable for commercial rates, provides services to residents of the nearby residential areas, e.g. shops, pubs and cafes.
- Existing habitable dwellings (properties with gardens larger than 1 acre may be required to register for the RZLT, notwithstanding that there may be no tax liability).
- Land used for certain facilities/infrastructure, i.e. land on hospital grounds, schools and train stations.
This list is not exhaustive.
Deferral of the RZLT
If an RZLT liability arises in respect of zoned and serviced land, a deferral of the RZLT is possible in certain circumstances:
- Where there is an ongoing appeal or judicial review related to the RZLT maps.
- Where planning permission cannot proceed due to an appeal to An Bord Pleanála, or a judicial review regarding the grant of planning permission.
- Where residential development has commenced on a site.
- In the 12-month period after the date of grant of planning permission as long as the following conditions are met:
- The planning permission is not the subject of a relevant appeal or relevant petition
- Development has not yet commenced.
Revenue guidance states that it is essential for taxpayers to file an RZLT return in order for a deferral to be claimed. The RZLT liability may be enforced by Revenue if a return to claim a deferral is not filed on time.
Deferred RZLT liabilities may become partially or fully payable if any of the following occur:
- If an appeal or judicial review related to the RZLT maps does not rule in favour of the landowner.
- If An Bord Pleanála do not rule in favour of the landowner and planning permission is not granted.
- If residential development is not completed in the lifetime of the planning permission.
- If a deferral is claimed for residential development and the site is sold before residential development is complete.
- If a return to claim a deferral is not filed on time.
Non-compliance
If a landowner fails to fulfil their RZLT obligations, Revenue may withhold the landowner’s tax clearance certificate.
Where a relevant site is undervalued in a return submitted to Revenue, surcharges of up to 30% of the RZLT can be imposed. Interest at 8% per year could also be applied on any outstanding RZLT liabilities.
Sale of land within scope of the RZLT
There are specific requirements where there is a sale of a property, or a site that falls within the scope of the RZLT.
Prior to the completion of a sale, the owner must file an RZLT return with Revenue. This return requires the unique identification number issued by Revenue, which is provided when an owner registers the site. In addition, certain information in relation to the relevant site, the liable person and the purchaser must be included on the return.
Before completion of a sale, a vendor is required to do the following in order to get RZLT clearance from Revenue:
- Pay all outstanding tax and accrued interest.
- Seek to agree, or have determined, and pay any penalty due in respect of the site.
- Submit all outstanding RZLT returns, including the RZLT return required prior to the completion of the sale.
- Revenue will confirm the tax position of the relevant site at the date of sale which will outline the following:
- That there are no outstanding amounts of RZLT payable at the date of sale
- That there is unpaid tax, accrued interest or a penalty owing in respect of the relevant site at the date of sale. The amount of each of these liabilities will also be provided by Revenue.
Conclusion
We encourage all land and property owners to check if they may be subject to the RZLT by referring to the map provided by their local authority. This will help determine if they must register or pay the RZLT.
If a payment is required, the pay and file deadline is 23 May 2026.
If you have any questions in relation to the above, or if you would like to discuss this topic further, please contact a member of the Forvis Mazars tax team below: