By the time Minister for Finance Brian Cowen had reached the end of the second page of his 27-page Budget speech on Wednesday, he had reiterated his commitment to improve equality and opportunity for all in our society on no less than three occasions.

On the third occasion, he committed to reaching "full equality". Like Pandora's curiosity, this emphasis could be a source of unforeseen troubles for the Minister over the next 12 months.

Mr Cowen described his basic aim of seeing that everybody pays an appropriate amount of income tax relative to their ability to do so as being the cornerstone of tax equity. The cornerstone of his response to this objective has been the introduction of an annual overall cap on the extent to which specific tax incentives can be availed of.

This response has received a broad welcome and rightly so. It entails a complex mechanism to achieve an alternative minimum income tax rate of around 20 per cent for taxpayers who responded to various governments over the years to invest in otherwise uneconomic sectors.

The reality of course is that the opportunity to reduce or eliminate one's tax liability through the use of targeted tax incentives has been progressively eroded over several years through restrictions introduced in various budgets and finance acts.

These have included: restrictions on the offset of property-based tax allowances against all income in the case of unitised investment schemes entailing, typically, more than 13 investors;capping each taxpayer's annual offset against non-rental income to €31,750; denying relief for hotel allowances against all income, and limiting allowances for passive investors in most partnership based property schemes.

The effect of these measures has resulted in the opportunity to invest in infrastructure projects promoted by the Government through the introduction of targeted tax incentives, being limited only to taxpayers with very considerable sources of Irish rental income. It seems incongruous this could sit well with a Minister for Finance who is on record as being committed to opening the doors of opportunity for every citizen in Ireland and, specifically, to a greater degree of equity in our tax system.

As a consequence, the abolition of the aforementioned restrictions must surely be on the cards. This would enable PAYE taxpayers at all income levels to meaningfully re-invest the fruits of their labour in Government-targeted infrastructure projects and avail of some tax relief.

It would also address the inequality of limiting such opportunity to taxpayers whose principal income is Irish rental income.

Indecon International Economic Consultants, a consultancy employed by the Government to review sectoral based property tax incentive schemes over the past year, concluded that restrictions on capital allowances which focus exclusively on rental income shelter should be refocused to allow relief against all income.

The introduction of the circa 20 per cent alternative minimum income tax rate from 2007 and the phasing out and refocusing of the remaining property-based tax incentives should ensure that appropriate safeguards exist to avoid the abuse and potential erosion of the tax base for which the restrictions were brought in in the first place.

Hence, it can be argued that there is no basis for restricting tax-based property allowances for offset against rental income only in the circumstances we now find ourselves in.

The early opening up of property-based tax allowances against all income should also have a significant effect on the supply side. It would create a more competitive environment in which the Government's supply targets for increased childcare facilities, private nursing homes and private hospitals can be delivered on a timely basis, as well as creating equality and opportunity for all.

Pandora would be contented to see a burden shared with someone of ministerial, and likely higher, office.

David Kennedy is a tax partner in KPMG.