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Finance Act 2025

In short

This law, the Finance Act 2025, outlines various changes and updates to tax regulations across several categories, including income tax, corporation tax, capital gains tax, excise duties, value-added tax, stamp duties, and capital acquisitions tax. It details amendments to existing tax laws and introduces new provisions related to financial matters.

What it regulates

  • Universal Social Charge, Income Tax, Corporation Tax and Capital Gains Tax.
  • Excise duties on mineral oil, natural gas, solid fuel, tobacco products, and betting.
  • Value-Added Tax (VAT) rates and exemptions.
  • Stamp Duties and Capital Acquisitions Tax.

Who it concerns

  • Individuals and companies subject to Universal Social Charge, Income Tax, Corporation Tax, and Capital Gains Tax.
  • Businesses and consumers affected by excise duties, Value-Added Tax, and stamp duties.
  • Individuals and entities involved in capital acquisitions.

Key points

  • Amends sections related to rent tax credit, mortgage interest tax relief, and the Help to Buy scheme.
  • Introduces an automatic enrolment retirement savings system.
  • Adjusts wear and tear allowances for energy-efficient equipment, gas vehicles, and farm safety equipment.
  • Modifies rates and reliefs for various excise duties, including tobacco products tax.
Legal text
Legal text

Finance Act 2025 Skip to content Disclaimer Feedback Helpdesk Gaeilge Léim go dtí an t-ábhar Séanadh Aiseolas Deasc chabhrach English Gaeilge English Produced by the Office of the Attorney General Táirgthe ag Oifig an Ard-Aighne Home Legislation Acts of the Oireachtas Statutory Instruments Pre-1922 Legislation Constitution External Resources Bills (Houses of the Oireachtas) Iris Oifigiúil / Official Gazette Revised Acts (LRC) Classified List of Legislation (LRC) Translations (acts.

  1. ie)Translations (Houses of the Oireachtas) Government Publications for Sale EU Law (EUR-Lex) FAQ Disclaimer Feedback Helpdesk Search Baile Reachtaíocht Achtanna an Oireachtais Ionstraimí Reachtúla Reachtaíocht Réamh-1922 Bunreacht Acmhainní Seachtracha Billí (Tithe an Oireachtais) Iris Oifigiúil Achtanna Athbhreithnithe (CAD) (An Coimisiún um Athchóiriú an Dlí) Liosta Rangaithe Reachtaíochta Aistriúcháin (achtanna.
  2. ie)Aistriúcháin (Tithe an Oireachtais) Foilseacháin Rialtais ar Díol Dlí AE (EUR-Lex) CCanna (Ceisteanna Coitianta) Séanadh Aiseolas Deasc chabhrach Cuardach TitleTeideal Year(
  3. s)or rangeBliain nó blianta nó raon TypeCineál All Legislation Acts Statutory Instruments Advanced SearchCuardach Casta HomeBaile ActsAchtanna 2025 Finance Act 2025 Finance Act 2025 Permanent Page URL View by SectionAmharc de réir Ailt View Full ActAmharc ar an Acht Iomlán Bill History Stair Bille Commencement, Amendments, SIs made under the Act Tosach Feidhme, Leasuithe, IRí arna ndéanamh faoin Acht Open PDFOscail PDF Print Full ActPriontáil an tAcht Iomlán Number 18 of 2025 FINANCE ACT 2025 CONTENTS PART 1 Universal Social Charge, Income Tax, Corporation Tax and Capital Gains Tax Chapter 1 Interpretation Section 1. Definition (Part 1) Chapter 2 Universal Social Charge 2. Amendment of section 531AN of Principal Act (rate of charge) Chapter 3 Income Tax 3. Amendment of section 473B of Principal Act (rent tax credit) 4. Amendment of section 473C of Principal Act (mortgage interest tax relief) 5. Amendment of section 477C of Principal Act (Help to Buy) 6. Amendment of section 204B of Principal Act (exemption in respect of compensation for certain living donors) 7. Amendment of section 208B of Principal Act (charities - miscellaneous) 8. Amendment of section 235 of Principal Act (bodies established for promotion of athletic or amateur games or sports) 9. Amendment of section 847A of Principal Act (donations to certain sports bodies) 10. Amendment of section 531AM of Principal Act (charge to universal social charge) 11. Amendment of section 847AA of Principal Act (deduction for donations to National Governing Bodies) 12. Amendment of section 216D of Principal Act (certain profits of micro-generation of electricity) 13. Amendment of section 216F of Principal Act (exemption of certain profits arising from production, maintenance and repair of certain musical instruments) 14. Annual returns by qualifying fund managers 15. Repeal of section 14 of Finance Act 2024 16. Automatic enrolment retirement savings system 17. Repeal of section 15 of Finance Act 2024 18. Automatic enrolment retirement savings system (amendments consequential on insertion of Chapter 2E in Part 30) 19. Amendment of section 128F of Principal Act (key employee engagement programme) 20. Amendment of Schedule 13 to Principal Act (accountable persons for purposes of Chapter 1 of Part 18) 21. Amendment of section 530A of Principal Act (principal to whom relevant contracts tax applies) 22. Amendment of section 823A of Principal Act (deduction for income earned in certain foreign states) 23. Amendment of section 825C of Principal Act (special assignee relief programme) 24. Amendment of section 121 of Principal Act (benefit of use of car) 25. Amendment of section 121A of Principal Act (benefit of use of van) Chapter 4 Income Tax, Corporation Tax and Capital Gains Tax 26. Amendment of section 285A of Principal Act (acceleration of wear and tear allowances for certain energy-efficient equipment) 27. Amendment of section 285C of Principal Act (acceleration of wear and tear allowances for gas vehicles and refuelling equipment) 28. Amendment of section 285D of Principal Act (acceleration of wear and tear allowances for farm safety equipment) 29. Amendment of section 658A of Principal Act (farming: accelerated allowances for capital expenditure on slurry storage) 30. Living City Initiative 31. Amendment of section 97B of Principal Act (deduction for retrofitting expenditure) 32. Estimate of tax due 33. Exemption of certain profits or gains arising from cost rental properties 34. Amendment of Schedule 4 to Principal Act (Exemption of Specified Non-Commercial State Sponsored Bodies from Certain Tax Provisions) 35. Amendment of Chapter 2 of Part 29 of Principal Act (scientific and certain other research) 36. Taxation of certain foreign body corporates 37. Life assurance policies and investment funds 38. Amendment of section 731 of Principal Act (chargeable gains accruing to unit trusts) 39. Exemption from dividend withholding tax for certain investment limited partnerships 40. Amendment to section 835AVB of Principal Act (collective investment scheme) 41. Amendments relating to group payments Chapter 5 Corporation Tax 42. Enhanced deduction for eligible construction expenditure 43. Amendment of section 291A of Principal Act (intangible assets) 44. Amendment of section 400 of Principal Act (company reconstructions without change of ownership) 45. Amendment of section 481 of Principal Act (relief for investment in films) 46. Amendment of section 481A of Principal Act (relief for investment in digital games) 47. Amendment of section 831B of Principal Act (participation exemption for certain foreign distributions) 48. Amendment of section 835AY of Principal Act (interpretation (Part 35D)) 49. Amendment of section 840A of Principal Act (interest on loans to defray money applied for certain purposes) 50. Amendment of section 891H of Principal Act (country-by-country reporting) Chapter 6 Capital Gains Tax 51. Amendment of section 597AA of Principal Act (revised entrepreneur relief) 52. Amendment of section 604B of Principal Act (relief for farm restructuring) PART 2 Excise 53. Amendment of Chapter 1 of Part 2 of Finance Act 1999 (Mineral Oil Tax) 54. Amendment of section 71 of Finance Act 2010 (reliefs from natural gas carbon tax) 55. Amendment of section 82 of Finance Act 2010 (reliefs from solid fuel carbon tax) 56. Amendment of Schedule 2 to Finance Act 2005 (rates of tobacco products tax) 57. Amendment of section 64 of Finance Act 2002 (interpretation) 58. Time when duty becomes due 59. Amendment of section 70 of Finance Act 2002 (returns) 60. Amendment of section 71 of Finance Act 2002 (payment of duty with bet) 61. Amendment of section 77 of Finance Act 2002 (regulations for payment of duty on bets) 62. De-registration of bookmaking premises 63. Repeal of Chapter III of Part II of Finance Act 1992 (Amusement Machine Licence Duty) 64. Amendment of section 68A of Finance Act 2002 65. Amendment of section 135 of Finance Act 1992 (temporary exemption from registration) 66. Amendment of section 135C of Finance Act 1992 (remission or repayment in respect of vehicle registration tax, etc.) PART 3 Value-Added Tax 67. Definition (Part 3) 68. Persons not accountable persons unless they so elect 69. Amendment of section 46 of Principal Act (reduced rate for electricity and gas) 70. Amendment of section 46 of, and Schedule 3 to, Principal Act (reduced rate for housing as part of a social policy) 71. Amendment of section 46 of Principal Act (reduced rate for food and drink for human consumption and hairdressing services) 72. Amendment of sections 60 and 120 of, and paragraph 11 of Schedule 3 to, Principal Act 73. Amendment of section 86 of Principal Act (special provisions for tax invoiced by flat-rate farmers) 74. Amendment of section 96 of Principal Act (waiver of exemption under old rules) 75. Amendments consequential on amendment of section 96 of Principal Act 76. Amendment of section 115 of Principal Act (penalties generally) 77. Amendment of paragraph 6

(2)of Schedule 1 to Principal Act (financial services) PART 4 Stamp Duties
  1. Definition (Part 4)
  2. Amendment of section 83D of Principal Act (repayment of stamp duty where land used for residential development)
  3. Miscellaneous amendments to Principal Act
  4. Land: special provisions
  5. Amendment of Part 7 of Principal Act (Exemptions and Reliefs from Stamp Duty)
  6. Amendment of section 126AB of Principal Act (further levy on certain financial institutions)
  7. Levy on authorised insurers
  8. Amendment of section 81AA of Principal Act (transfers to young trained farmers)
  9. Amendment of section 81C of Principal Act (further farm consolidation relief) PART 5 Capital Acquisitions Tax
  10. Definition (Part 5)
  11. Amendment of section 41 of Principal Act (when interest in assurance policy becomes interest in possession)
  12. Amendment of Chapter 2 of Part 10 of Principal Act (business relief)
  13. Assessment of executors and administrators PART 6 Miscellaneous
  14. Definition (Part 6)
  15. Implementation of Part I of OECD
(2023)International Standards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework
  1. Amendment of section 811C of Principal Act (transactions to avoid liability to tax)
  2. Amendment of section 891F of Principal Act (returns of certain information by financial institutions)
  3. Amendment of Part 4A of Principal Act (Implementation of Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union)
  4. Amendment of section 638A of Principal Act (company mergers and divisions)
  5. Amendment of section 851A of Principal Act (confidentiality of taxpayer information)
  6. Amendment of section 869 of Principal Act (delivery, service and evidence of notices and forms)
  7. Amendment of section 959AA of Principal Act (chargeable persons: time limit on assessment made or amended by Revenue officer)
  8. Amendment of section 959AP of Principal Act (payment of preliminary tax by direct debit)
  9. Amendment of section 959AU of Principal Act (date for payment of tax: amended assessments)
  10. Amendment of section 959I of Principal Act (obligation to make a return)
  11. Residential zoned land tax
  12. Technical amendments to de minimis aid provisions
  13. Miscellaneous technical amendments in relation to tax
  14. Care and management of taxes and duties
  15. Short title, construction and commencement SCHEDULE Miscellaneous Technical Amendments in Relation to Tax Acts Referred to Affordable Housing Act 2021 (No. 25) Automatic Enrolment Retirement Savings System Act 2024 (No. 20) Betting Act 1931 (No. 27) Capital Acquisitions Tax Consolidation Act 2003 (No. 1) Companies Act 2014 (No. 38) Finance Act 1992 (No. 9) Finance Act 1999 (No. 2) Finance Act 2002 (No. 5) Finance Act 2005 (No. 5) Finance Act 2008 (No. 3) Finance Act 2010 (No. 5) Finance Act 2024 (No. 43) Gambling Regulation Act 2024 (No. 35) Greyhound Industry Act 1958 (No. 12) Housing (Miscellaneous Provisions) Act, 1979 (No. 27) Housing Act 1966 (No. 21) Human Tissue (Transplantation, Post-Mortem, Anatomical Examination and Public Display) Act 2024 (No. 5) Investment Limited Partnerships Act 1994 (No. 24) Irish Horseracing Industry Act 1994 (No. 18) Local Government Rates and Other Matters Act 2019 (No. 24) Planning and Development Act 2000 (No. 30) Planning and Development Act 2024 (No. 34) Stamp Duties Consolidation Act 1999 (No. 31) Taxes Consolidation Act 1997 (No. 39) Valuation Act 2001 (No. 13) Value-Added Tax Consolidation Act 2010 (No. 31) Number 18 of 2025 FINANCE ACT 2025 An Act to provide for the imposition, repeal, remission, alteration and regulation of taxation, of stamp duties and of duties relating to excise and otherwise to make further provision in connection with finance; and to provide for related matters. [23rd December, 2025] Be it enacted by the Oireachtas as follows: PART 1 Universal Social Charge, Income Tax, Corporation Tax and Capital Gains Tax Chapter 1 Interpretation Definition (Part 1)
  16. In this Part, “Principal Act” means the Taxes Consolidation Act 1997 . Chapter 2 Universal Social Charge Amendment of section 531AN of Principal Act (rate of charge) 2.
(1)Section 531AN of the Principal Act is amended— (a) in subsection
(3), by the substitution of “€28,700” for “€27,382”, (b) in subsection
(4), by the substitution of “2028” for “2026”, and (c) by the substitution of the following for Part 1 of the Table to that section: “PART 1 Part of aggregate income
(1)Rate of universal social charge
(2)The first €12,012 0.5 per cent The next €16,688 2 per cent The next €41,344 3 per cent The remainder 8 per cent ”.
(2)Subsection
(1)applies for the year of assessment 2026 and each subsequent year of assessment. Chapter 3 Income Tax Amendment of section 473B of Principal Act (rent tax credit) 3. Section 473B of the Principal Act is amended by the substitution of the following subsection for subsection
(14): “
(14)This section shall apply in respect of the years of assessment 2022 to 2028 (both years inclusive).”. Amendment of section 473C of Principal Act (mortgage interest tax relief) 4. Section 473C of the Principal Act is amended— (a) in subsection
(1)— (
  1. i)by the substitution of the following definition for the definition of “qualifying period”: “ ‘qualifying period’ means— (
  2. a)for the purposes of subsection
(4), the period commencing on 1 January 2023 and ending on 31 December 2023, (
  1. b)for the purposes of subsection (4A), the period commencing on 1 January 2024 and ending on 31 December 2024, (
  2. c)for the purposes of subsection (4B), the period commencing on 1 January 2025 and ending on 31 December 2025, and (
  3. d)for the purposes of subsection (4C), the period commencing on 1 January 2026 and ending on 31 December 2026;”, (
  4. ii)by the substitution of the following definition for the definition of “relievable interest”: “ ‘relievable interest’ has the meaning given to it— (
  5. a)by subsection
(4), in the case of the year of assessment 2023, (
  1. b)by subsection (4A), in the case of the year of assessment 2024, (
  2. c)by subsection (4B), in the case of the year of assessment 2025, and (
  3. d)by subsection (4C), in the case of the year of assessment 2026;”, and (iii) by the substitution of the following definition for the definition of “upper limit”: “ ‘upper limit’ means— (
  4. a)€6,250 for the years of assessment 2023, 2024 and 2025, (
  5. b)€3,125 for the year of assessment 2026, or (
  6. c)where subsection
(5), (5A), (5B) or (5C) apply, the amount determined in accordance with paragraph (a)(i), (a)(
  1. ii)or (b), as the case may be, of the subsection concerned.”, (
  2. b)in subsection
(2), by the substitution of “a qualifying period referred to in paragraph (a), (b), (c) or (d), as the case may be, of the definition, in subsection
(1), of that term” for “a qualifying period referred to in paragraph (a) or (b), as the case may be, of the definition of that term in subsection
(1)”, (
  1. c)by the insertion of the following subsections after subsection (4A): “(4B) (
  2. a)For the purposes of this section, in respect of a claim under subsection
(2)for the year of assessment 2025, relievable interest, in relation to an individual, shall be an amount determined by the formula— A – B where— A is the amount of qualifying interest for the year of assessment 2025, and B is the amount of qualifying interest for the year of assessment 2022. (
  1. b)Where qualifying interest paid for a year of assessment referred to in paragraph (
  2. a)is for a period where the number of days in the years of assessment to which ‘A’ and ‘B’ in the formula in paragraph (
  3. a)relate are not the same, the amount of qualifying interest represented by ‘A’ or ‘B’, as the case may be, in the formula in paragraph (
  4. a)shall— (
  5. i)where the number of days in the year of assessment to which ‘A’ relates is greater than the number of days in the year of assessment to which ‘B’ relates, be determined by the following formula— A x D/E and (
  6. ii)where the number of days in the year of assessment to which ‘B’ relates is greater than the number of days in the year of assessment to which ‘A’ relates, be determined by the following formula— B x D/E where— D is the number of days in the year of assessment with the lesser number of days, and E is the number of days in the year of assessment with the greatest number of days. (4C) (
  7. a)For the purposes of this section, in respect of a claim under subsection
(2)for the year of assessment 2026, relievable interest, in relation to an individual, shall be an amount determined by the formula— (A – B) x 50 per cent where— A is the amount of qualifying interest for the year of assessment 2026, and B is the amount of qualifying interest for the year of assessment 2022. (
  1. b)Where qualifying interest paid for a year of assessment referred to in paragraph (
  2. a)is for a period where the number of days in the years of assessment to which ‘A’ and ‘B’ in the formula in paragraph (
  3. a)relate are not the same, the amount of qualifying interest represented by ‘A’ or ‘B’, as the case may be, in the formula in paragraph (
  4. a)shall— (
  5. i)where the number of days in the year of assessment to which ‘A’ relates is greater than the number of days in the year of assessment to which ‘B’ relates, be determined by the following formula— A x D/E and (
  6. ii)where the number of days in the year of assessment to which ‘B’ relates is greater than the number of days in the year of assessment to which ‘A’ relates, be determined by the following formula— B x D/E where— D is the number of days in the year of assessment with the lesser number of days, and E is the number of days in the year of assessment with the greatest number of days.”, (
  7. d)by the insertion of the following subsections after subsection (5A): “(5B) Where, for the year of assessment 2025, qualifying interest referred to in subsection (4B) is for a period of less than 365 days, then— (
  8. a)where— (
  9. i)the number of days in the year of assessment to which ‘A’ in the formula in subsection (4B) relates is less than 365 and the number of days in the year of assessment to which ‘B’ in the formula in subsection (4B) relates is equal to 365, or (
  10. ii)the number of days in the year of assessment to which ‘B’ in the formula in subsection (4B) relates is less than 365 and the number of days in the year of assessment to which ‘A’ in the formula in subsection (4B) relates is equal to 365, the upper limit shall be determined by the formula— F x G/H or (
  11. b)where the number of days in the year of assessment to which ‘A’ in the formula in subsection (4B) relates is less than 365 and the number of days in the year of assessment to which ‘B’ in the formula in subsection (4B) relates is less than 365, then, the upper limit shall be determined by the formula— F x I/J where— F is €6,250, G is the number of days in the year of assessment with the lesser number of days, H is the number of days in the year of assessment with the greater number of days, I is the number of days in the year of assessment with the lesser number of days, and J is 365 days. (5C) Where, for the year of assessment 2026, qualifying interest referred to in subsection (4C) is for a period of less than 365 days, then— (
  12. a)where— (
  13. i)the number of days in the year of assessment to which ‘A’ in the formula in subsection (4C) relates is less than 365 and the number of days in the year of assessment to which ‘B’ in the formula in subsection (4C) relates is equal to 365, or (
  14. ii)the number of days in the year of assessment to which ‘B’ in the formula in subsection (4C) relates is less than 365 and the number of days in the year of assessment to which ‘A’ in the formula in subsection (4C) relates is equal to 365, the upper limit shall be determined by the formula— F x G/H or (
  15. b)where the number of days in the year of assessment to which ‘A’ in the formula in subsection (4C) relates is less than 365 and the number of days in the year of assessment to which ‘B’ in the formula in subsection (4C) relates is less than 365, then, the upper limit shall be determined by the formula— F x I/J where— F is €3,125, G is the number of days in the year of assessment with the lesser number of days, H is the number of days in the year of assessment with the greater number of days, I is the number of days in the year of assessment with the lesser number of days, and J is 365 days.”, (
  16. e)in subsection
(7)(a), by the substitution of “a qualifying period referred to in paragraph (a), (b), (c) or (d), as the case may be, of the definition, in subsection
(1), of that term” for “a qualifying period referred to in paragraph (a) or (b), as the case may be, of the definition of that term in subsection
(1)”, (f) in subsection
(8)(a), by the substitution of “the calendar year 2023, 2024, 2025 or 2026, as the case may be,” for “the calendar year 2023 or 2024, as the case may be,”, (g) in subsection
(9)(b), by the substitution of “subsection
(4), (4A), (4B) or (4C), as the case may be” for “subsection
(4)or (4A), as the case may be”, and (h) in subsection
(11)(e), by the substitution of the following subparagraphs for subparagraphs (
  1. i)and (ii): “(
  2. i)the qualifying interest paid by the claimant for— (I) the year of assessment 2022, (II) the qualifying period referred to in paragraph (
  3. a)of the definition, in subsection
(1), of that term to which the claim relates, (III) the qualifying period referred to in paragraph (b) of the definition, in subsection
(1), of that term to which the claim relates, (IV) the qualifying period referred to in paragraph (c) of the definition, in subsection
(1), of that term to which the claim relates, or (V) the qualifying period referred to in paragraph (d) of the definition, in subsection
(1), of that term to which the claim relates, (ii) where subsection
(9)(
  1. b)applies, the total qualifying interest paid by all of the individuals concerned for— (I) the year of assessment 2022, (II) the qualifying period referred to in paragraph (
  2. a)of the definition, in subsection
(1), of that term to which the claim relates, (III) the qualifying period referred to in paragraph (b) of the definition, in subsection
(1), of that term to which the claim relates, (IV) the qualifying period referred to in paragraph (c) of the definition, in subsection
(1), of that term to which the claim relates, or (V) the qualifying period referred to in paragraph (d) of the definition, in subsection
(1), of that term to which the claim relates, and”. Amendment of section 477C of Principal Act (Help to Buy) 5. Section 477C of the Principal Act is amended, with effect as on and from 26 November 2025, in subparagraph (ii) of the definition in subsection
(1)of “qualifying residence”, by the substitution of “paragraph (c) or (cac), as the case may be, of section 46
(1)” for “section 46
(1)(c)”. Amendment of section 204B of Principal Act (exemption in respect of compensation for certain living donors) 6. Section 204B of the Principal Act is amended by the substitution of “subsections
(3)and
(4)of section 12 of the Human Tissue (Transplantation, Post-Mortem, Anatomical Examination and Public Display) Act 2024 ” for “Regulation 21
(2)of the European Union (Quality and Safety of Human Organs Intended for Transplantation) Regulations 2012 ( S.I. No. 325 of 2012 )”. Amendment of section 208B of Principal Act (charities - miscellaneous) 7. Section 208B of the Principal Act is amended by the insertion of the following subsection after subsection
(3): “(3A) (
  1. a)An exemption under section 207 or 208, as the case may be, shall apply from the date of the notice of the determination under section 864, on a claim under section 207 or 208, granting the exemption. (
  2. b)An exemption under section 208A shall apply from the date of the notice of the determination under that section granting the exemption.”. Amendment of section 235 of Principal Act (bodies established for promotion of athletic or amateur games or sports) 8. Section 235
(2)of the Principal Act is amended by the insertion of “, and the exemption shall apply from the date of the notice of the determination under section 864 on a claim, under this section, granting the exemption” after “subsection
(1)(a)”. Amendment of section 847A of Principal Act (donations to certain sports bodies) 9. Section 847A of the Principal Act is amended— (a) in subsection
(1), by the insertion of the following definitions: “ ‘approved project number’ has the meaning given to it by subsection
(4)(aa); ‘unique receipt number’ has the meaning given to it by subsection
(16)(b)(vii).”, (b) in subsection
(4), by the insertion of the following paragraph after paragraph (a): “(
  1. aa)Where the Minister gives a certificate to a body in respect of a project under paragraph (a), the Minister shall assign a unique number to the project (in this section referred to as an ‘approved project number’) and include that number in the certificate.”, (
  2. c)in subsection
(9)— (
  1. i)by the substitution of the following paragraph for paragraph (b): “(
  2. b)For the purposes of paragraph (a)(i), any such deduction or set-off shall not be taken into account in determining in respect of the individual or, as the case may be, the individual’s spouse or civil partner— (
  3. i)the remuneration of the office or employment for the purposes of section 774
(7)(
  1. c)of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment, or (
  2. ii)net relevant earnings within the meaning of section 787, 787B or 787X, as the case may be, of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment,”, and (
  3. ii)by the insertion of the following paragraph after paragraph (e): “(
  4. f)An election made under paragraph (
  5. a)is irrevocable with effect from the date that is the earliest of— (
  6. i)the specified return date for the chargeable period, within the meaning of section 959A, in respect of the return referred to in paragraph (d), (
  7. ii)the date on which the return referred to in paragraph (
  8. d)is delivered, or (iii) 1 December in the year following the year in which the relevant donation was made.”, (
  9. d)in subsection
(11)— (
  1. i)by the substitution of the following paragraph for paragraph (b): “(
  2. b)For the purposes of paragraph (a)(i), any such deduction or set-off shall not be taken into account in determining, in respect of the individual or, as the case may be, the individual’s spouse or civil partner— (
  3. i)the remuneration of the office or employment for the purposes of section 774
(7)(
  1. c)of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment, or (
  2. ii)net relevant earnings within the meaning of section 787, 787B or 787X, as the case may be, of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment.”, (
  3. ii)in paragraph (d)— (I) in subparagraph (ii), by the substitution of “in subsection
(16),” for “in subsection
(16), and”, and (II) by the insertion of the following subparagraphs after subparagraph (ii): “(iia) the approved project number, (iib) the unique receipt number, and”, and (iii) by the insertion of the following paragraph after paragraph (e): “(
  1. f)An election made under paragraph (
  2. a)is irrevocable with effect from the date that is the earlier of— (
  3. i)the date on which a claim is made under paragraph (d), or (
  4. ii)1 December in the year following the year in which the relevant donation was made.”, (
  5. e)in subsection
(12), by the substitution of “subsection
(9)(a)(ii)(II) or subsection
(11)(a)(ii)(II), as the case may be,” for “subsection
(11)(b)”, and (f) in subsection
(16)(b)— (
  1. i)in subparagraph (v), by the substitution of “issued,” for “issued, and”, and (
  2. ii)by the insertion of the following subparagraphs after subparagraph (vi): “(vii) a unique number assigned by the approved sports body in respect of the relevant donation (in this section referred to as a “unique receipt number”), and (viii) the approved project number,”. Amendment of section 531AM of Principal Act (charge to universal social charge) 10. Section 531AM of the Principal Act is amended, in paragraph (b)(viii)(II) of the Table to that section— (
  3. a)in subclause (D), by the deletion of “or”, and (
  4. b)by the insertion of the following subclause after subclause (D): “(DA) under section 847AA in respect of a relevant donation (within the meaning of that section), or”. Amendment of section 847AA of Principal Act (deduction for donations to National Governing Bodies) 11. Section 847AA of the Principal Act is amended— (
  5. a)in subsection
(1)— (
  1. i)in the definition of “elite athlete”, by the insertion of “or” after “Sport Ireland International Carding Scheme,”, (
  2. ii)in paragraph (a)(
  3. ii)of the definition of “national governing body”, by the substitution of “Minister,” for “Minister for Tourism, Culture, Arts, Gaeltacht, Sports and Media,”, and (iii) by the insertion of the following definitions: “ ‘qualifying project number’ has the meaning given to it by subsection
(8)(aa); ‘unique receipt number’ has the meaning given to it by subsection
(9).”, (b) in subsection
(4)— (
  1. i)by the substitution of the following paragraph for paragraph (c): “(
  2. c)For the purposes of paragraph (a)(i), any such deduction or set-off shall not be taken into account in determining in respect of the individual or, as the case may be, the individual’s spouse or civil partner— (
  3. i)the remuneration of the office or employment for the purposes of section 774
(7)(
  1. c)of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment, or (
  2. ii)net relevant earnings within the meaning of section 787, 787B or 787X, as the case may be, of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment.”, (
  3. ii)in paragraph (e)— (I) in subparagraph (ii), by the substitution of “in subsection
(9),” for “in subsection
(9)and”, (II) by the insertion of the following subparagraphs after subparagraph (ii): “(iia) the qualifying project number, (iib) the unique receipt number, and”, and (iii) by the insertion of the following paragraph after paragraph (f): “(
  1. g)An election made under paragraph (
  2. a)is irrevocable from the date that is the earlier of— (
  3. i)the date on which the claim referred to in paragraph (
  4. e)is made, or (
  5. ii)1 December in the year following the year in which the relevant donation was made.”, (
  6. c)in subsection
(5)— (
  1. i)by the substitution of the following paragraph for paragraph (c): “(
  2. c)For the purposes of paragraph (a)(i), any such deduction or set-off shall not be taken into account in determining in respect of the individual or, as the case may be, the individual’s spouse or civil partner— (
  3. i)the remuneration of the office or employment for the purposes of section 774
(7)(
  1. c)of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment, or (
  2. ii)net relevant earnings, within the meaning of section 787, 787B or 787X, as the case may be, of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment.”, and (
  3. ii)by the insertion of the following paragraph after paragraph (f): “(
  4. g)An election made under paragraph (
  5. a)is irrevocable from the date that is the earliest of— (
  6. i)the specified return date for the chargeable period, within the meaning of section 959A, in respect of the return referred to in paragraph (e), (
  7. ii)the date on which the return referred to in paragraph (
  8. e)is delivered, or (iii) 1 December in the year following the year in which the relevant donation was made.”, (
  9. d)in subsection
(8), by the insertion of the following paragraph after paragraph (a): “(
  1. aa)Where the Minister gives a certificate to a body in respect of a project under paragraph (a), the Minister shall assign a unique number to the project (in this section referred to as a ‘qualifying project number’) and shall include that number in the certificate.”, and (
  2. e)in subsection
(9)— (
  1. i)by the substitution of “shall, on the acceptance of a relevant donation, assign a unique number to the donation (in this section referred to as a ‘unique receipt number’) and give to the person” for “shall, on acceptance of a relevant donation, give to the person”, and (
  2. ii)in paragraph (b)— (I) in subparagraph (iv), by the deletion of “and”, and (II) in subparagraph (v), by the deletion of “and”, and (III) by the insertion of the following subparagraphs after subparagraph (v): “(
  3. vi)the qualifying project number, and (vii) the unique receipt number, and”. Amendment of section 216D of Principal Act (certain profits of micro-generation of electricity) 12. Section 216D of the Principal Act is amended, in subsection
(1), in the definition of “relevant period”, by the substitution of “31 December 2028” for “31 December 2025”. Amendment of section 216F of Principal Act (exemption of certain profits arising from production, maintenance and repair of certain musical instruments) 13. Section 216F
(1)of the Principal Act is amended by the substitution of the following definition for the definition of “relevant period”: “ ‘relevant period’ means any of the years of assessment 2023 to 2028 (both years inclusive);”. Annual returns by qualifying fund managers 14.
(1)Part 30 of the Principal Act is amended by the insertion of the following section after section 784B: “784BA.
(1)In this section— ‘electronic means’ has the same meaning as it has in section 917EA; ‘fund holder’ means the individual beneficially entitled to the assets in the approved retirement fund; ‘qualifying fund manager’ has the same meaning as it has in section 784A; ‘tax reference number’ has the same meaning as it has in section 784A.
(2)A qualifying fund manager shall, within 3 months of the end of the year of assessment, make a return to the Revenue Commissioners, by electronic means, in respect of all approved retirement funds which the qualifying fund manager administered in that year of assessment.
(3)For the purposes of a return under this section, the qualifying fund manager shall provide to the Revenue Commissioners the following information in respect of each approved retirement fund that the qualifying fund manager administers: (
  1. a)the name and address of the fund holder; (
  2. b)the tax reference number of the fund holder; (
  3. c)the date on which the approved retirement fund was first held by the fund holder; (
  4. d)the country of residence of the fund holder; (
  5. e)the number of approved retirement funds administered by the qualifying fund manager on behalf of each fund holder; (
  6. f)details and value of the assets held in the approved retirement fund, including: (
  7. i)asset type and location; (
  8. ii)details of any income, profits or chargeable gains derived from those assets during the year of assessment concerned; (iii) details of any assets acquired and or disposed of during the year of assessment concerned; (
  9. iv)details of any distributions made in the year of assessment to which the return relates; (
  10. g)in respect of a transaction deemed to be a distribution for the purposes of this Chapter: (
  11. i)the name and address of the person to whom the distribution was made; (
  12. ii)the amount of the distribution; (iii) the tax which the qualifying fund manager is required to account for in relation to that distribution; (
  13. h)such other information in relation to assets held in, and distributions made from, the approved retirement fund as the Revenue Commissioners may require for the purposes of this section.
(4)A return under this section shall be in a form prescribed or authorised by the Revenue Commissioners and shall include a declaration to the effect that the return is correct and complete.
(5)A person who is required to make a return under this section and who— (a) fails to comply with any of the requirements of subsections
(2)or
(3), as the case may be, or (b) makes an incorrect or incomplete return under this section, shall, for each such failure, be liable to a penalty of €3,000.”.
(2)Subsection
(1)applies for the year of assessment 2026 and each subsequent year of assessment. Repeal of section 14 of Finance Act 2024
  1. Section 14 of the Finance Act 2024 is repealed. Automatic enrolment retirement savings system
  2. Part 30 of the Principal Act is amended by the insertion of the following Chapter after Chapter 2D: “CHAPTER 2E AUTOMATIC ENROLMENT RETIREMENT SAVINGS SYSTEM Interpretation (Chapter 2E) 787AE. In this Chapter— ‘Act of 2024’ means the Automatic Enrolment Retirement Savings System Act 2024 ; ‘AE provider scheme’ has the same meaning as it has in the Act of 2024; ‘Authority’ has the same meaning as it has in the Act of 2024; ‘balance’ has the same meaning as it has in Part 5 of the Act of 2024; ‘contributing participant’ has the same meaning as it has in the Act of 2024; ‘contribution’ has the same meaning as it has in the Act of 2024; ‘emoluments’ has the same meaning as it has in Chapter 4 of Part 42; ‘employee’ has the same meaning as it has in Chapter 4 of Part 42; ‘employer’ has the same meaning as it has in Chapter 4 of Part 42; ‘employer contribution’ has the same meaning as it has in the Act of 2024; ‘participant’ has the same meaning as it has in the Act of 2024; ‘participant account’, in relation to a participant, means the account maintained for the participant by the Authority under section 76 of the Act of 2024; ‘personal representative’ has the same meaning as it has in Part 5 of the Act of 2024; ‘State contribution’ has the same meaning as it has in the Act of 2024; ‘unit’, in relation to an AE provider scheme, has the same meaning as it has in Part 4 of the Act of
  3. Allowance to employer 787AF.
(1)For the purposes of this section, ‘chargeable period’ means an accounting period of a company or a year of assessment.
(2)Subject to subsection
(3), any employer contribution in respect of a contributing participant shall, for the purposes of Case I or II of Schedule D and of sections 83 and 707
(4), be allowed to be deducted as an expense, or expense of management, incurred in the chargeable period in which the sum is paid but no other sum shall for those purposes be allowed to be deducted as an expense, or expense of management, in respect of the making, or any provision for the making, of any such contributions.
(3)The amount of an employer contribution which may be deducted under subsection
(2)shall not exceed the amount contributed by that employer to the Authority in respect of an employee in a trade or undertaking in respect of the profits of which the employer is assessable to income tax or corporation tax, as the case may be. Repayments to employer 787AG. Where a repayment of employer contributions is made or becomes due to an employer under section 64 of the Act of 2024 as a result of an overpayment of contributions to the Authority, the repayment shall be treated for the purposes of the Tax Acts as a receipt of that trade or undertaking receivable when the repayment is due or on the last day on which the trade or undertaking is carried on by the employer, whichever is the earlier. Exemption of AE provider schemes 787AH.
(1)Exemption from income tax shall, on a claim being made in that behalf, be allowed in respect of income derived from investments or deposits of assets held in an AE provider scheme if it is income from investments or deposits held for the purposes of the scheme.
(2)(
  1. a)In this subsection, ‘financial futures’ and ‘traded options’ mean, respectively, financial futures and traded options for the time being dealt in or quoted on any futures exchange or any stock exchange, whether or not that exchange is situated in the State. (
  2. b)For the purposes of subsection
(1), a contract entered into in the course of dealing in financial futures or traded options shall be regarded as an investment.
(3)Exemption from income tax shall, on a claim being made in that behalf, be allowed in respect of underwriting commissions if the underwriting commissions are applied for the purposes of the AE provider scheme and in respect of which the Authority would, but for this subsection, be chargeable to tax under Case IV of Schedule D.
(4)(
  1. a)A unit in an AE provider scheme is not an asset of a pension fund for the purposes of Chapter 1A of Part 27. (
  2. b)For the purpose of this subsection, a unit referred to in paragraph (
  3. a)includes a unit (within the meaning of section 739B) in an investment undertaking (within the said meaning) held by a participant. Taxation of payments from automatic enrolment retirement savings system 787AI.
(1)Subject to subsections
(2)and
(3)— (a) the payment of the balance from a participant account, after any lump sum withdrawn in accordance with subsection
(3)(a), shall, notwithstanding anything in section 18 or 19, be treated as a payment to the participant of emoluments to which Schedule E applies and, accordingly, the provisions of Chapter 4 of Part 42 shall apply to any such payment or amount treated as a payment, and (b) the Authority shall deduct tax from the balance held in that participant’s account at the higher rate for the year of assessment in which the balance is made available unless the Authority has received from the Revenue Commissioners a revenue payroll notification (within the meaning of section 983) for that year in respect of the participant.
(2)The Authority shall be liable to pay to the Collector-General the income tax which the Authority is required to deduct from any balance withdrawn by a participant by virtue of this section and the individual beneficially entitled to the balance withdrawn by that participant from their participating account, including the personal representatives of a deceased individual who was so entitled prior to the individual’s death, shall allow such deduction; but where there are no funds or insufficient funds available out of which the Authority may satisfy the tax required to be deducted, the amount of such tax for which there are insufficient funds available shall be a debt due to the Authority from the individual beneficially entitled to the balance held in the participant account or from the estate of the deceased individual, as the case may be.
(3)Subsection
(1)shall not apply where the balance from a participant account is— (a) an amount made available, at the time the balance of the participant account is first made available to the participant, by way of lump sum (in accordance with section 83
(1)(
  1. a)of the Act of 2024) not exceeding 25 per cent of the value of the balance at that time, or (
  2. b)an amount made available to the personal representatives of the participant following the death of the participant and before the giving of a notification under section 82
(1)(d) of the Act of 2024 by the Authority.
(4)(a) Where the payment of the balance referred to in subsection
(1)is made following the death of the participant who was prior to death beneficially entitled to the assets of the participant account, the amount of the funds shall be treated as the income of that participant for the year of assessment in which that participant dies and, subject to paragraph (b), subsection
(1)shall apply accordingly. (b) Subsection
(1)shall not apply to a payment made of the balance following the death of the participant, where the giving of a notification under section 82
(1)(
  1. d)of the Act of 2024 by the Authority is made to— (
  2. i)a spouse or civil partner of the participant, or (
  3. ii)any child of the participant or any child of the spouse or civil partner of the participant. (
  4. c)Where, in a case referred to in paragraph (b), the payment of the balance is made to a person who had attained the age of 21 years at the date of death of the participant beneficially entitled to the assets in the participant account, the Authority shall deduct income tax from the distribution under Case IV of Schedule D at a rate of 30 per cent, and— (
  5. i)the amount so charged to tax— (I) shall not be reckoned in computing total income for the purposes of the Tax Acts, and (II) shall be computed without regard to any amount deductible from, or deductible in computing, total income for the purposes of the Tax Acts, (
  6. ii)the charging of the balance in such manner shall be without any relief or reduction specified in the Table to section 458, or any other deduction from that distribution, and (iii) section 188 shall not apply as regards the amount so charged. (
  7. d)Where the Authority deducts tax in accordance with paragraph (c), subsections
(8)to
(15)of section 790AA shall, with any necessary modifications, apply as if any reference in those subsections— (
  1. i)to the administrator were a reference to the Authority, and (
  2. ii)to an excess lump sum were a reference to the balance of a kind referred to in paragraph (c).”. Repeal of section 15 of Finance Act 2024 17. Section 15 of the Finance Act 2024 is repealed. Automatic enrolment retirement savings system (amendments consequential on insertion of Chapter 2E in Part 30) 18.
(1)The Principal Act is amended— (a) in section 118, by the insertion of the following subsection after subsection (5L): “(5M) Subsection
(1)shall not apply to expense incurred by the body corporate in the provision for an employee (within the meaning of Chapter 2E of Part 30) of a contribution (within the said meaning).”, (
  1. b)in Part 7, by the insertion of the following section after section 192P: “Exemption in respect of State contribution under automatic enrolment retirement savings system 192Q. A State contribution (within the meaning of the Automatic Enrolment Retirement Savings System Act 2024 ) shall be exempt from income tax and shall not be reckoned in computing total income for the purposes of the Income Tax Acts or in computing amounts chargeable to universal social charge in accordance with Part 18D.”, (
  2. c)in section 246
(3)— (
  1. i)in paragraph (i), by the substitution of “such subsidiary,” for “such subsidiary, or”, (
  2. ii)in paragraph (j), by the substitution of “such subsidiary,” for “such subsidiary.”, and (iii) by the insertion of the following paragraphs after paragraph (j): “(
  3. k)interest paid to the Authority (within the meaning of Chapter 2E of Part 30), or (
  4. l)interest paid by the Authority (within the meaning of Chapter 2E of Part 30).”, (
  5. d)in section 256
(1), in the definition of “relevant deposit”— (
  1. i)in paragraph (a)— (I) in subparagraph (v), by the substitution of “The Investor Compensation Company Limited,” for “The Investor Compensation Company Limited, or”, (II) in subparagraph (vi), by the substitution of “Icarom plc, or” for “Icarom plc,”, and (III) by the insertion of the following subparagraph after subparagraph (vi): “(vii) An tÚdarás Náisiúnta um Uathrollú Coigiltis Scoir,”, (
  2. ii)in paragraph (k), by the substitution of “Revenue Commissioners,” for “Revenue Commissioners, or”, (iii) in paragraph (l), by the substitution of “relevant deposit taker, or” for “relevant deposit taker;”, and (
  3. iv)by the insertion of the following paragraph after paragraph (l): “(
  4. m)which is made by the Authority (within the meaning of Chapter 2E of Part 30) in respect of contributions (within the meaning of the Automatic Enrolment Retirement Savings System Act 2024 ) made to the Authority;”, (
  5. e)in section 531AM, in paragraph (
  6. a)of the Table to that section— (
  7. i)in clause (VI), by the deletion of “and”, (
  8. ii)in clause (VII), by the substitution of “(within the meaning of Chapter 2D of Part 30) and,”, for “(within the meaning of Chapter 2D of Part 30).”, and (iii) by the insertion of the following clause after clause (VII): “(VIII) emoluments in the nature of a contribution by an employer to the Authority (within the meaning of Chapter 2E of Part 30).”, (
  9. f)in section 608
(2), by the substitution of “PEPP assets (within the meaning of Chapter 2D of Part 30) or held by or on behalf of that person as units in an AE provider scheme (within the meaning of Chapter 2E of Part 30)” for “PEPP assets (within the meaning of Chapter 2D of Part 30)”, (g) in section 706
(3), by the insertion of the following paragraph after paragraph (e): “(
  1. f)any contract with an AE provider scheme (within the meaning of Chapter 2E of Part 30);”, (
  2. h)in section 739B
(1), by the insertion of the following definitions: “ ‘AE provider scheme’ has the same meaning as it has in Chapter 2E of Part 30; ‘Authority’ has the same meaning as it has in Chapter 2E of Part 30; ‘participant’ has the same meaning as it has in Chapter 2E of Part 30;”, (i) in section 739D
(6), by the insertion of the following paragraph after paragraph (kc): “(
  1. kd)holds units in an AE provider scheme, registered in the name of the Authority on behalf of a participant and the Authority has made a declaration to that effect to the investment undertaking,”, (
  2. j)in section 787O
(1)— (
  1. i)in the definition of “administrator”— (I) in paragraph (d), by the substitution of “section 787U,” for “section 787U, and”, (II) in paragraph (e), by the substitution of “Chapter 2D, and” for “Chapter 2D;”, and (III) by the insertion of the following paragraph after paragraph (e): “(
  2. f)An tÚdarás Náisiúnta um Uathrollú Coigiltis Scoir;”, (
  3. ii)in the definition of “member”, by the substitution of “Chapter 2D, a participant within the meaning of Chapter 2E” for “Chapter 2D”, (iii) in the definition of “relevant pension arrangement”— (I) in paragraph (f), by the substitution of “paragraph (e),” for “paragraph (e), or”, (II) in paragraph (g), by the substitution of “that Chapter, or” for “that Chapter;”, and (III) by the insertion of the following paragraph after paragraph (g): “(
  4. h)the automatic enrolment retirement savings system established, maintained and controlled by the Authority (within the meaning of Chapter 2E) under the Automatic Enrolment Retirement Savings System Act 2024 ;”, and (
  5. iv)by the insertion of the following definition: “ ‘participant’ has the same meaning as it has in Chapter 2E;”, and (
  6. k)in section 790AA
(1)(a), in the definition of “relevant pension arrangement”— (
  1. i)in subparagraph (vii), by the substitution of “that Chapter,” for “that Chapter;”, and (
  2. ii)by the insertion of the following subparagraph after subparagraph (vii): “(viii) the automatic enrolment retirement savings system established, maintained and controlled by the Authority (within the meaning of Chapter 2E) under the Automatic Enrolment Retirement Savings System Act 2024 ;”.
(2)Section 85 of the Capital Acquisitions Tax Consolidation Act 2003 is amended by the substitution of the following subsection for subsection
(1): “
(1)In this section— ‘Act of 1997’ means the Taxes Consolidation Act 1997 ; ‘Act of 2024’ means the Automatic Enrolment Retirement Savings System Act 2024 ; ‘Authority’ has the same meaning as it has in the Act of 2024; ‘balance’ has the same meaning as it has in section 78 of the Act of 2024; ‘participant’ has the same meaning as it has in the Act of 2024; ‘participant account’, in relation to a participant, means the account maintained for the participant by the Authority under section 76 of the Act of 2024; ‘retirement fund’, in relation to an inheritance taken on death of a disponer, means— (a) a fund that is— (i) an approved retirement fund or an approved minimum retirement fund, within the meaning of section 784A or 784C of the Act of 1997, (ii) a Personal Retirement Savings Account, within the meaning of section 787A of the Act of 1997, where assets of the Personal Retirement Savings Account are treated under subsection
(4)or (4B), as the case may be, of section 787G of that Act as having been made available to an individual, (iii) a vested RAC within the meaning of section 787O
(1)of the Act of 1997, or (iv) a PEPP, within the meaning of Chapter 2D of Part 30 of the Act of 1997, where assets of the PEPP are treated under subsection
(4)or
(6), as the case may be, of section 787AA of that Act as having been made available to an individual, being wholly comprised of all or any of the following, that is— (I) property which represents in whole or in part the accrued rights of the disponer, or of a predeceased spouse or civil partner of the disponer, under— (A) an annuity contract or retirement benefits scheme approved by the Commissioners for the purposes of Chapter 1 or 2 of Part 30 of the Act of 1997, or (B) a Personal Retirement Savings Account being a PRSA product approved by the Commissioners for the purposes of Chapter 2A of Part 30 of the Act of 1997, (II) any accumulations of income of such property, (III) property which represents in whole or in part these accumulations, or (IV) a PEPP, within the meaning of Chapter 2D of Part 30 of the Act of 1997, registered for the purposes of that Chapter under Article 7 of Regulation (EU) No. 2019/1238 of the European Parliament and Council of 20 June 20191 , or (b) the balance in a participant’s account, where the Authority sent a notification to the participant, in accordance with section 82
(1)(d) of the Act of 2024, that such balance was eligible for withdrawal.”.
(3)Section 82C
(1)of the Stamp Duties Consolidation Act 1999 is amended, in the definition of “pension scheme”— (
  1. a)in paragraph (g), by the substitution of “that Chapter, or” for “that Chapter;”, and (
  2. b)by the insertion of the following paragraph after paragraph (g): “(
  3. h)an AE provider scheme within the meaning of the Automatic Enrolment Retirement Savings System Act 2024 ;”. Amendment of section 128F of Principal Act (key employee engagement programme) 19.
(1)Section 128F of the Principal Act is amended— (a) in subsection
(1)— (
  1. i)in the definition of “excluded activities”, by the substitution of the following paragraph for paragraph (c): “(
  2. c)financing activities,”, and (
  3. ii)by the substitution of the following definition for the definition of “financial activities”: “ ‘financing activities’ has the same meaning as in section 489;”, (
  4. b)in subsection
(3), by the substitution of “1 January 2029” for “1 January 2026”, and (c) in subsection (6A)(a), by the substitution of “1 January 2029” for “1 January 2026”.
(2)Paragraphs (
  1. b)and (
  2. c)of subsection
(1)shall come into operation on such day as the Minister for Finance may appoint by order. Amendment of Schedule 13 to Principal Act (accountable persons for purposes of Chapter 1 of Part 18) 20. Schedule 13 to the Principal Act is amended— (
  1. a)by the substitution of the following paragraph for paragraph 69: “69. Temple Bar Cultural Trust Designated Activity Company.”, and (
  2. b)by the insertion of the following paragraphs after paragraph 217: “218. Taighde Éireann. 219. Judicial Appointments Commission. 220. Comhlacht Formhaoirsithe Seachtrach Óglaigh na hÉireann. 221. Gambling Regulatory Authority of Ireland. 222. oifig an Scrúdaitheora Neamhspleách um Reachtaíocht Slándála.”. Amendment of section 530A of Principal Act (principal to whom relevant contracts tax applies) 21. Section 530A of the Principal Act is amended, in subsection
(1), by the substitution of the following paragraph for paragraph (d): “(d) a local authority, a public utility society (within the meaning of section 2 of the Housing Act 1966 ), a body referred to in section 45 of the Housing Act 1966 and approved for the purposes of the said section 45 or a body referred to in subsection
(1)of section 7 of the Housing (Miscellaneous Provisions) Act 1979 and approved for the purposes of the said section 7 .”. Amendment of section 823A of Principal Act (deduction for income earned in certain foreign states) 22. Section 823A of the Principal Act is amended— (a) in subsection
(1)— (
  1. i)by the substitution of the following definition for the definition of “qualifying day”: “ ‘qualifying day’, in relation to an office or employment of an individual, means a day— (
  2. a)which is one throughout the whole of which the individual is present in a relevant state for the purposes of the performance of the duties of the office or employment, (
  3. b)where such day is substantially devoted to the performance of such duties, and (
  4. c)which shall not be counted more than once as a qualifying day;”, and (
  5. ii)by the substitution of the following definition for the definition of “relevant state”: “ ‘relevant state’ means, as regards the years of assessment 2012 to 2025, the Russian Federation, and as regards the years of assessment 2012 to 2030, the Federative Republic of Brazil, the Republic of India, the People’s Republic of China or the Republic of South Africa, and includes— (
  6. a)as regards the years of assessment 2013 to 2030, the Arab Republic of Egypt, the People’s Democratic Republic of Algeria, the Republic of Senegal, the United Republic of Tanzania, the Republic of Kenya, the Federal Republic of Nigeria, the Republic of Ghana and the Democratic Republic of the Congo, (
  7. b)as regards the years of assessment 2015 to 2030, Japan, the Republic of Singapore, the Republic of Korea, the Kingdom of Saudi Arabia, the United Arab Emirates, the State of Qatar, the Kingdom of Bahrain, the Republic of Indonesia, the Socialist Republic of Vietnam, the Kingdom of Thailand, the Republic of Chile, the Sultanate of Oman, the State of Kuwait, the United Mexican States and Malaysia, (
  8. c)as regards the years of assessment 2017 to 2030, the Republic of Colombia and the Islamic Republic of Pakistan, and (
  9. d)as regards the years of assessment 2026 to 2030, the Republic of the Philippines and the Republic of Türkiye;”, (
  10. b)by the insertion of the following subsection after subsection
(1): “(1A) For the purposes of the definition, in subsection
(1), of ‘qualifying day’— (
  1. a)presence in a relevant state shall include the duration of time spent travelling directly from the State to a relevant state, and from a relevant state to the State or to another relevant state, (
  2. b)a day shall be a qualifying day only where the individual’s presence in the relevant state is reasonably required for the purposes of the performance of the duties of the office or employment, and (
  3. c)a day shall not be precluded from being a qualifying day solely on the grounds that the duties of the office or employment could have been performed in the State on that day.”, (
  4. c)by the substitution of the following subsection for subsection
(3): “
(3)Where for any year of assessment an individual resident in the State makes a claim in that behalf to and satisfies an authorised officer that either— (
  1. a)the number of days in that year which are qualifying days in relation to an office or employment of the individual (together with any days which are qualifying days in relation to any other such office or employment of the individual), or (
  2. b)the number of such days referred to in paragraph (
  3. a)in a relevant period in relation to that year and no part of which period is comprised in any other relevant period, amounts to at least 30 days, there shall be deducted from the income, profits or gains of the individual from all offices or employments assessable under Schedule D or E, as may be appropriate, an amount equal to the specified amount in relation to that office or employment or those offices or employments but that amount, or the aggregate of those amounts where there is more than one such office or employment, shall not exceed €50,000.”, and (
  4. d)in subsection
(6), by the substitution of “2015 to 2030” for “2015 to 2025”. Amendment of section 825C of Principal Act (special assignee relief programme) 23. Section 825C of the Principal Act is amended— (
  1. a)by the insertion of the following subsection after subsection (2AA): “(2AB) In this section, in the case of an individual who arrives in the State in any of the tax years 2026 to 2030, ‘relevant employee’ means an individual— (
  2. a)who, for the whole of the 6 months immediately before his or her arrival in the State, was a full time employee of a relevant employer and exercised the duties of his or her employment for that relevant employer outside the State, (
  3. b)who arrives in the State at the request of his or her relevant employer— (
  4. i)to perform in the State duties of his or her employment for that employer, or (
  5. ii)to take up employment in the State with an associated company and to perform duties in the State for that company, (
  6. c)who performs the duties referred to in paragraph (
  7. b)for a minimum period of 12 consecutive months from the date he or she first performs those duties in the State, (
  8. d)who, for the year of arrival in the State, is entitled to receive income, profits or gains from an employment with a relevant employer or an associated company, which, after excluding the amounts referred to at paragraphs (
  9. a)to (
  10. h)of the definition, in subsection
(1), of ‘relevant income’, is not less than the annualised equivalent of €125,000, (
  1. e)to whom a PPS number has been issued, (
  2. f)who was not resident in the State for the 5 tax years immediately preceding the tax year in which he or she first arrives in the State for the purposes of performing the duties referred to in paragraph (b), and (
  3. g)in respect of whom the relevant employer or associated company certifies, in such form as the Revenue Commissioners may require, within 90 days from the employee’s arrival in the State to perform the duties referred to in paragraph (b), that— (
  4. i)the individual complies with the conditions set out in paragraphs (
  5. a)to (e), and (
  6. ii)the relevant employer or associated company has complied with Regulation 17
(2)of the Income Tax (Employments) Regulations 2018 ( S.I. No. 345 of 2018 ), but where such certification is made after 90 days but within 180 days from the date of the employee’s arrival in the State, the individual shall be deemed to be a relevant employee for the purposes of this section.”, (b) in subsection (2B)(b)— (i) in subparagraph (i)— (I) by the substitution of “referred to in subsection
(2)(a)(ii), (2A)(b), (2AA)(b) or (2AB)(b)” for “referred to in subsection
(2)(a)(ii), (2A)(
  1. b)or (2AA)(b)”, and (II) in subclause (B), by the substitution of “set out in subsection (2A)(b), (2AA)(
  2. b)or (2AB)(b)” for “set out in subsection (2A)(
  3. b)or (2AA)(b)”, and (
  4. ii)by the substitution of the following subparagraph for subparagraph (ii)— “(
  5. ii)‘B’ is €75,000 or, in the case of a relevant employee who arrives in the State— (I) in any of the tax years 2023 to 2025, €100,000, or (II) in any of the tax years 2026 to 2030, €125,000.”, (
  6. c)in subsection
(3)— (
  1. i)in paragraph (a)— (I) by the substitution of the following subparagraph for subparagraph (ii): “(
  2. ii)performs the duties referred to in subsection
(2)(a)(ii), (2A)(b), (2AA)(
  1. b)or (2AB)(b), and”, and (II) by the substitution of the following subparagraph for subparagraph (iii): “(iii) has relevant income from his or her relevant employer or from the associated company, the annualised equivalent of which is— (I) subject to clauses (II) and (III), not less than €75,000, (II) in the case of a relevant employee who arrives in the State in any of the tax years 2023 to 2025, not less than €100,000, or (III) in the case of a relevant employee who arrives in the State in any of the tax years 2026 to 2030, not less than €125,000,”, and (
  2. ii)by the substitution of the following subparagraph for subparagraph (c): “(
  3. c)(
  4. i)A relevant employee, other than a relevant employee referred to in subsection (2AB), shall only be entitled to relief under this section for 5 consecutive tax years, commencing with the tax year for which the relevant employee is first entitled to relief under this section. (
  5. ii)A relevant employee referred to in subsection (2AB) shall only be entitled to relief under this section for— (I) 5 consecutive tax years, commencing with the tax year for which the relevant employee is first entitled to relief under this section, where the certification referred to in paragraph (
  6. g)of subsection (2AB) is made within 90 days from the employee’s arrival in the State, or (II) 4 consecutive tax years, commencing with the tax year after which the relevant employee is first entitled to relief under this section, where the certification referred to in paragraph (
  7. g)of subsection (2AB) is made after 90 days but within 180 days from the employee’s arrival in the State.”, (
  8. d)in subsection
(4)(b)— (
  1. i)by the substitution of “2030” for “2025”, and (
  2. ii)in subparagraph (i), by the substitution of “set out in subsection (2A)(b), (2AA)(
  3. b)or (2AB)(b)” for “set out in subsection (2A)(
  4. b)or (2AA)(b)”, and (
  5. e)in subsection
(10), by the substitution of “30 June” for “23 February”. Amendment of section 121 of Principal Act (benefit of use of car) 24. Section 121(4A) of the Principal Act is amended— (a) in paragraph (a), by the substitution of “column
(3),
(4),
(5),
(6),
(7)or
(8)” for “column
(3),
(4),
(5),
(6)or
(7)”, (
  1. b)in paragraph (aa)— (
  2. i)in subparagraph (iv), by the substitution of “subject to paragraph (ab), €20,000” for “€20,000”, and (
  3. ii)in subparagraph (v), by the substitution of “subject to paragraph (ab), €10,000” for “€10,000”, (
  4. c)in paragraph (ab)— (
  5. i)by the substitution of “each of the years of assessment 2023 to 2028 (both years inclusive)” for “the years of assessment 2023, 2024 and 2025”, (
  6. ii)in subparagraph (i)— (I) by the substitution of “subparagraph (i), (ii), (iii), (
  7. iv)or (v)” for “subparagraph (i), (
  8. ii)or (iii)”, (II) in clause (I), by the substitution of “subparagraph (i), (ii), (iii), (
  9. iv)or (v)” for “subparagraph (i), (
  10. ii)or (iii)”, (III) by the substitution of the following for clause (II): “(II) €10,000 for each of the years of assessment 2023 to 2026 (both years inclusive), €5,000 for the year of assessment 2027 and €2,500 for the year of assessment 2028,”, and (iii) in subparagraph (ii)— (I) by the substitution of “A1, A, B, C and D” for “A, B, C and D”, and (II) by the substitution of “an amount ascertained under clause (II)” for “€10,000”, (
  11. d)in paragraph (b), by the substitution of “column
(3),
(4),
(5),
(6),
(7)or
(8)” for “column
(3),
(4),
(5),
(6)or
(7)” in both places where it occurs, and (
  1. e)in paragraph (d)— (
  2. i)by the substitution of the following Table for Table A: “TABLE A Business Mileage Vehicle Categories Lower limit
(1)Upper limit
(2)A1
(3)A
(4)B
(5)C
(6)D
(7)E
(8)Kilometres Kilometres Per cent Per cent Per cent Per cent Per cent Per cent — 26,000 15 22.5 26.25 30 33.75 37.5 26,001 39,000 12 18 21 24 27 30 39,001 48,000 9 13.5 15.75 18 20.25 22.5 48,001 — 6 9 10.5 12 13.5 15 ”, and (ii) by the substitution of the following Table for Table B: “TABLE B Vehicle Category
(1)CO2 Emissions (CO2 g/km)
(2)A1 0g/km A More than 0g/km up to and including 59g/km B More than 59g/km up to and including 99g/km C More than 99g/km up to and including 139g/km D More than 139g/km up to and including 179g/km E More than 179g/km ”. Amendment of section 121A of Principal Act (benefit of use of van) 25. Section 121A
(2)(
  1. b)of the Principal Act is amended— (
  2. a)in subparagraph (vii)— (
  3. i)in clause (IV), by the substitution of “subject to subparagraph (viii), €20,000” for “€20,000”, and (
  4. ii)in clause (V), by the substitution of “subject to subparagraph (viii), €10,000” for “€10,000”, and (
  5. b)in subparagraph (viii)— (
  6. i)by the substitution of “each of the years of assessment 2023 to 2028 (both years inclusive)” for “the years of assessment 2023, 2024 and 2025”, (
  7. ii)in clause (I)— (I) by the substitution of “clause (I), (II), (III), (IV) or (V)” for “clause (I), (II) or (III)”, (II) in subclause (A), by the substitution of “clause (I), (II), (III), (IV) or (V)” for “clause (I), (II) or (III)”, and (III) by the substitution of the following subclause for subclause (B): “(B) €10,000 for each of the years of assessment 2023 to 2026 (both years inclusive), €5,000 for the year of assessment 2027 and €2,500 for the year of assessment 2028,”, and (iii) in clause (II), by the substitution of “an amount ascertained under clause (I) (B)” for “€10,000”. Chapter 4 Income Tax, Corporation Tax and Capital Gains Tax Amendment of section 285A of Principal Act (acceleration of wear and tear allowances for certain energy-efficient equipment) 26. Section 285A of the Principal Act is amended, in subsection
(1), in the definition of “relevant period”, by the substitution of “31 December 2030” for “31 December 2025”. Amendment of section 285C of Principal Act (acceleration of wear and tear allowances for gas vehicles and refuelling equipment) 27. Section 285C of the Principal Act is amended, in subsection
(1), in the definition of “relevant period”, by the substitution of “31 December 2030” for “31 December 2025”. Amendment of section 285D of Principal Act (acceleration of wear and tear allowances for farm safety equipment) 28. Section 285D of the Principal Act is amended, in subsection
(18)— (
  1. a)in paragraph (b), by the substitution of “, Regulation (EU) 2019/1243 of the European Parliament and of the Council of 20 June 20192 and Commission Delegated Regulation (EU) 2023/137 of 10 October 20223 ” for “and Regulation (EU) 2019/1243 of the European Parliament and of the Council of 20 June 20194 ”, and (
  2. b)in paragraph (c), by the substitution of “Commission Delegated Regulation (EU) 2019/1755 of 8 August 20195 and Commission Delegated Regulation (EU) 2023/674 of 26 December 20226 ” for “and Commission Delegated Regulation (EU) 2019/1755 of 8 August 20197 ”. Amendment of section 658A of Principal Act (farming: accelerated allowances for capital expenditure on slurry storage) 29. Section 658A of the Principal Act is amended— (
  3. a)in subsection
(1), in the definition of “relevant period”, by the substitution of “31 December 2029” for “31 December 2025”, and (b) in subsection
(7)— (
  1. i)in paragraph (b), by the substitution of “, Regulation (EU) 2019/1243 of the European Parliament and of the Council of 20 June 20198 and Commission Delegated Regulation (EU) 2023/137 of 10 October 20229 ” for “and Regulation (EU) 2019/1243 of the European Parliament and of the Council of 20 June 201910 ”, and (
  2. ii)in paragraph (c), by the substitution of “, Commission Delegated Regulation (EU) 2019/1755 of 8 August 201911 and Commission Delegated Regulation (EU) 2023/674 of 26 December 202212 ” for “and Commission Delegated Regulation (EU) 2019/1755 of 8 August 201913 ”. Living City Initiative 30. The Principal Act is amended— (
  3. a)in section 372AAA
(1)— (
  1. i)in the definition of “qualifying period”, by the substitution of “31 December 2030” for “31 December 2027”, (
  2. ii)in the definition of “relevant house”, by the substitution of “1975” for “1915”, and (iii) by the insertion of the following definitions: “ ‘Commission Regulation (EU) 2023/2831’ means Commission Regulation (EU) 2023/2831 of 13 December 202314 on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union to de minimis aid; ‘de minimis aid’ means aid granted in compliance with Commission Regulation (EU) 2023/2831; ‘permissible ceiling of aid’ means the maximum amount of de minimis aid of €300,000 that may be granted to a single undertaking over any period of 3 years in accordance with Commission Regulation (EU) 2023/2831; ‘single undertaking’ has the meaning given to it by Article 2
(2)of Commission Regulation (EU) 2023/2831;”, (
  1. b)in section 372AAC— (
  2. i)in subsection
(1)— (I) by the deletion of the definition of “property developer”, and (II) by the substitution of the following definition for the definition of “qualifying expenditure”: “ ‘qualifying expenditure’, means, notwithstanding section 279, capital expenditure incurred in the qualifying period on the conversion or the refurbishment of a qualifying premises after deducting from that amount of expenditure any sum in respect of or by reference to— (
  1. a)that expenditure, (
  2. b)the qualifying premises, or (
  3. c)the conversion work, or as the case may be, the refurbishment work in respect of which that expenditure was incurred, which the person has received or is entitled to receive, directly or indirectly, from the State, any board established by statute or any public or local authority, and for the purposes of giving relief under this section, any reference to expenditure being incurred shall include a reference to expenditure deemed under any provision of Part 9 to be incurred;”, (
  4. ii)by the deletion of subsection (1A), (iii) by the substitution of the following subsection for subsection
(4): “
(4)(
  1. a)In relation to qualifying expenditure incurred before 1 January 2026 in the qualifying period on a qualifying premises, section 272 shall apply as if— (
  2. i)in subsection
(3)(a)(
  1. ii)of that section the reference to 4 per cent were a reference to 15 per cent, and (
  2. ii)in subsection
(4)(
  1. a)of that section the following were substituted for subparagraph (ii): ‘(
  2. ii)where capital expenditure on the conversion or refurbishment of the building or structure is incurred, 7 years beginning with the time when the building or structure was first used subsequent to the incurring of that expenditure.’. (
  3. b)In relation to qualifying expenditure incurred on or after 1 January 2026 in the qualifying period on a qualifying premises, section 272 shall apply as if— (
  4. i)in subsection
(3)(a)(
  1. ii)of that section the reference to 4 per cent were a reference to 50 per cent, and (
  2. ii)in subsection
(4)(
  1. a)of that section the following were substituted for subparagraph (ii): ‘(
  2. ii)where capital expenditure on the conversion or refurbishment of the building or structure is incurred, 10 years beginning with the time when the building or structure was first used subsequent to the incurring of that expenditure.’.”, (
  3. iv)by the substitution of the following subsection for subsection
(5): “
(5)Notwithstanding section 274
(1), no balancing allowance or balancing charge shall be made in relation to a qualifying premises by reason of any event referred to in that section which occurs more than— (
  1. a)7 years after the qualifying premises was first used subsequent to the incurring of the qualifying expenditure on the conversion or refurbishment of the qualifying premises where that qualifying expenditure was incurred before 1 January 2026, or (
  2. b)10 years after the qualifying premises was first used subsequent to the incurring of the qualifying expenditure on the conversion or refurbishment of the qualifying premises where that qualifying expenditure was incurred on or after 1 January 2026.”, (
  3. v)by the deletion of subsections
(8), (8A) and
(10), and (vi) by the insertion of the following subsection after subsection
(10): “
(11)A claim for relief in accordance with this section may only be made by a person insofar as the aggregate of the claim, when taken together with other de minimis aid received, does not exceed the permissible ceiling of aid to the single undertaking of which the person is a part.”, (c) in section 372AAD— (i) in subsection
(1)— (I) by the deletion of the definition of “property developer”, (II) by the substitution of the following definition for the definition of “eligible expenditure”: “ ‘eligible expenditure’, means, notwithstanding section 279, capital expenditure incurred in the relevant qualifying period on the conversion or the refurbishment of a special qualifying premises after deducting from that amount of expenditure any sum in respect of or by reference to— (
  1. a)that expenditure, (
  2. b)the special qualifying premises, or (
  3. c)the conversion work, or as the case may be, the refurbishment work in respect of which that expenditure was incurred, which the person has received or is entitled to receive, directly or indirectly, from the State, any board established by statute or any public or local authority, and for the purposes of giving relief under this section, any reference to expenditure being incurred shall include a reference to expenditure deemed under any provision of Part 9 to be incurred;”, and (III) in the definition of “relevant qualifying period”, by the substitution of “31 December 2030” for “31 December 2027”, (
  4. ii)by the deletion of subsection
(2), (iii) by the substitution of the following subsection for subsection
(4): “
(4)(
  1. a)In relation to eligible expenditure incurred before 1 January 2026 in the relevant qualifying period on a special qualifying premises, section 272 shall apply as if— (
  2. i)in subsection
(3)(a)(
  1. ii)of that section the reference to 4 per cent were a reference to 15 per cent, and (
  2. ii)in subsection
(4)(
  1. a)of that section the following were substituted for subparagraph (ii): ‘(
  2. ii)where capital expenditure on the conversion or refurbishment of the building or structure is incurred, 7 years beginning with the time when the building or structure was first used subsequent to the incurring of that expenditure.’. (
  3. b)In relation to eligible expenditure incurred on or after 1 January 2026 in the relevant qualifying period on a special qualifying premises, section 272 shall apply as if— (
  4. i)in subsection
(3)(a)(
  1. ii)of that section the reference to 4 per cent were a reference to 50 per cent, and (
  2. ii)in subsection
(4)(
  1. a)of that section the following were substituted for subparagraph (ii): ‘(
  2. ii)where capital expenditure on the conversion or refurbishment of the building or structure is incurred, 10 years beginning with the time when the building or structure was first used subsequent to the incurring of that expenditure.’.”, (
  3. iv)by the substitution of the following subsection for subsection
(7): “
(7)Notwithstanding section 274
(1), no balancing allowance or balancing charge shall be made in relation to a special qualifying premises by reason of any event referred to in that section which occurs more than— (
  1. a)7 years after the special qualifying premises was first used subsequent to the incurring of the eligible expenditure on the conversion or refurbishment of the special qualifying premises where that eligible expenditure was incurred before 1 January 2026, or (
  2. b)10 years after the special qualifying premises was first used subsequent to the incurring of the eligible expenditure on the conversion or refurbishment of the special qualifying premises where that eligible expenditure was incurred on or after 1 January 2026.”, (
  3. v)by the deletion of subsections
(10),
(11)and
(13), and (vi) by the insertion of the following subsection after subsection
(13): “
(14)A claim for relief in accordance with this section may only be made by a person insofar as the aggregate of that claim, when taken together with other de minimis aid received, does not exceed the permissible ceiling of aid to the single undertaking of which the person is a part.”, (d) by the insertion of the following section after section 372AAD: “Capital allowances in relation to conversion or refurbishment of certain qualifying premises 372AAE.
(1)In this section— ‘conversion’, ‘house’ and ‘letter of certification’ have the same meaning, respectively, as they have in section 372AAB; ‘qualifying expenditure’ means, notwithstanding section 279, capital expenditure incurred by a person in the relevant qualifying period on the conversion or the refurbishment of a qualifying premises after deducting from that amount of expenditure any sum in respect of or by reference to— (
  1. a)that expenditure, (
  2. b)the qualifying premises, or (
  3. c)the conversion work or, as the case may be, the refurbishment work in respect of which that expenditure was incurred, which the person has received or is entitled to receive, directly or indirectly, from the State, any board established by statute or any public or local authority and for the purposes of giving relief under this section, any reference to expenditure being incurred shall include a reference to expenditure deemed under any provision of Part 9 to be incurred; ‘qualifying premises’ means a building or structure (or part of a building or structure)— (
  4. a)the site of which is wholly within a special regeneration area, (
  5. b)the entirety of which, before the qualifying expenditure was incurred, was a relevant property liable to rates, (
  6. c)in respect of which a letter of certification has issued for its conversion or refurbishment, as the case may be, into one or more than one house, and (
  7. d)which, following the incurring of qualifying expenditure on its conversion or refurbishment, as the case may be, into one or more houses— (
  8. i)is, or the relevant portion thereof is, a relevant property not rateable, and (
  9. ii)the house or houses concerned are let on bona fide commercial terms for such consideration as might be expected to be paid in a letting of the house concerned negotiated on an arm’s length basis; ‘rate’ has the meaning assigned to it by section 4 of the Local Government Rates and Other Matters Act 2019 ; ‘relevant property’ shall be construed in accordance with Schedule 3 to the Valuation Act 2001 ; ‘relevant property not rateable’ means a property specified in paragraph 6 of Schedule 4 to the Valuation Act 2001 ; ‘relevant qualifying period’ means the period commencing on 1 January 2026 and ending on 31 December 2030.
(2)(
  1. a)Subject to paragraph (
  2. b)and subsections
(3)to
(8), the provisions of the Tax Acts relating to the making of allowances or charges in respect of capital expenditure incurred on the construction or refurbishment of an industrial building or structure shall, notwithstanding anything to the contrary in those provisions, apply in relation to qualifying expenditure on a qualifying premises as if the qualifying premises were, at all times at which it is a qualifying premises, an industrial building or structure in respect of which an allowance is to be made for the purposes of income tax or corporation tax, as the case may be, under Chapter 1 of Part 9 by reason of its use for the purpose specified in section 268
(1)(a). (b) An allowance shall be given by virtue of this subsection in relation to any qualifying expenditure on a qualifying premises only in so far as that expenditure is incurred in the relevant qualifying period.
(3)In relation to qualifying expenditure incurred in the relevant qualifying period on a qualifying premises, section 272 shall apply as if— (a) in subsection
(3)(a)(
  1. ii)of that section the reference to 4 per cent were a reference to 50 per cent, and (
  2. b)in subsection
(4)(
  1. a)of that section the following were substituted for subparagraph (ii): ‘(
  2. ii)where capital expenditure on the conversion or refurbishment of the building or structure is incurred, 10 years beginning with the time when the building or structure was first used subsequent to the incurring of that expenditure.’.
(4)Notwithstanding section 274
(1), no balancing allowance or balancing charge shall be made in relation to a qualifying premises by reason of any event referred to in that section which occurs more than 10 years after the qualifying premises was first used subsequent to the incurring of the qualifying expenditure on the conversion or refurbishment of the qualifying premises.
(5)This section shall not apply where qualifying expenditure incurred does not exceed €5,000.
(6)Relief under this section shall not be given unless the following information is provided to the Revenue Commissioners as part of the first claim made by the person in accordance with subsection
(2): (
  1. a)the name, address and tax reference number of the person making the claim; (
  2. b)the address of the qualifying premises in respect of which the qualifying expenditure was incurred; (
  3. c)details of the aggregate of all qualifying expenditure incurred by the person in respect of the qualifying premises.
(7)Any information required to be provided to the Revenue Commissioners under this section shall be provided by electronic means and through such electronic systems as the Revenue Commissioners may make available for the time being for any such purpose.
(8)For the purposes only of determining, in relation to a claim for an allowance by virtue of subsection
(2), whether and to what extent qualifying expenditure incurred on the conversion or refurbishment of a qualifying premises is incurred or not incurred in the relevant qualifying period, only such an amount of that expenditure as is properly attributable to work on the conversion or refurbishment of the qualifying premises actually carried out during the relevant qualifying period shall (notwithstanding any other provision of the Tax Acts as to the time when any capital expenditure is or is to be treated as incurred) be treated as having been incurred in that period.
(9)Where relief is given by virtue of this section in relation to capital expenditure incurred on the conversion or refurbishment of a building or structure, relief shall not be given in respect of that expenditure under any other provision of the Tax Acts.
(10)A claim for relief in accordance with this section may only be made by a person insofar as the aggregate of that claim, when taken together with other de minimis aid received, does not exceed the permissible ceiling of aid to the single undertaking of which the person is a part.”, (e) in section 409F
(2), in paragraph (
  1. a)of the definition of “area-based capital allowance”, by the substitution of “372AAC, 372AAD or 372AAE” for “372AAC or 372AAD”, and (
  2. f)in Schedule 25B, by insertion of the following after the matter set out opposite Reference Number 38C: “ 38D Section 372AAE (capital allowances in relation to conversion or refurbishment of certain qualifying premises) An amount equal to— (
  3. a)the aggregate amount of allowances (including balancing allowances) made to the individual under Chapter 1 of Part 9 as that Chapter is applied by section 372AAE, including any such allowance or part of any allowances made to the individual for a previous tax year and carried forward from that previous tax year in accordance with Part 9, or (
  4. b)where full effect has not been given in respect of that aggregate for that tax year, the part of that aggregate to which full effect has been given for that tax year in accordance with section 278 and section 304 or 305, as the case may be, or any of those sections as applied or modified by any other provision of the Tax Acts. ”. Amendment of section 97B of Principal Act (deduction for retrofitting expenditure) 31. Section 97B of the Principal Act is amended— (
  5. a)in subsection
(1), in the definition of “relevant period”, by the substitution of “31 December 2028” for “31 December 2025”, (b) by the substitution of the following subsection for subsection
(4): “
(4)Subject to subsections
(5)and
(6)— (a) where a person chargeable has incurred qualifying expenditure in the year of assessment 2023, 2024 or 2025, that person is entitled, in computing for the purposes of section 97
(1)the amount of a surplus or deficiency in respect of the rent from the qualifying premises concerned for the year of assessment following that in which the qualifying expenditure is incurred, to a deduction equal to the relevant amount, and (b) where a person chargeable has incurred qualifying expenditure in the year of assessment 2026 or any subsequent year of assessment, that person is entitled, in computing for the purposes of section 97
(1)the amount of a surplus or deficiency in respect of the rent from the qualifying premises concerned for the year of assessment in which the qualifying expenditure is incurred, to a deduction equal to the relevant amount.”, and (c) by the substitution of the following subsection for subsection
(5): “
(5)A person chargeable shall not be entitled to a deduction under subsection
(4)— (
  1. a)for qualifying expenditure incurred in the year of assessment 2023, 2024 or 2025, in respect of more than two qualifying premises, and (
  2. b)for qualifying expenditure incurred in the year of assessment 2026 or any subsequent year of assessment, in respect of more than three qualifying premises.”. Estimate of tax due 32. Part 41A of the Principal Act is amended, in Chapter 8, by the insertion of the following section after section 959AW: “959AX.
(1)Where a chargeable person fails to deliver a return in respect of a chargeable period in the prescribed form, on or before the specified return date for the chargeable period, in accordance with section 959I, for income tax or corporation tax, as appropriate, then, without prejudice to any other action which may be taken, a Revenue officer may, subject to subsection
(2), at any time estimate the amount of tax payable by the chargeable person in respect of that chargeable period and serve notice in writing on the chargeable person specifying the amount estimated in respect of income tax or corporation tax, as the case may be, for that chargeable period (in this section referred to as ‘the estimated tax’).
(2)For the purposes of subsection
(1), the estimated tax, in respect of the chargeable period concerned, shall be the greater of— (a) an amount based on the average amount of tax due that was included on the 2 most recent returns delivered by the chargeable person for income tax or corporation tax, as the case may be, before the service of the notice under subsection
(1), or (b) €1,000.
(3)The estimated tax specified in the notice served under subsection
(1)shall be recoverable in the same manner and by the like proceedings as if the chargeable person had delivered a return in respect of the chargeable period concerned in the prescribed form, on or before the specified return date for that chargeable period to which the notice relates, in accordance with section 959I, for income tax or corporation tax, as appropriate, showing the estimated tax as due by that person.
(4)If, within 30 days after the service of a notice under subsection
(1), in respect of the chargeable period to which the notice relates, the person— (
  1. a)delivers a return to the Revenue Commissioners in respect of that chargeable period and pays the tax due, if any, in accordance with the return, together with any interest, penalties and surcharge which may have been incurred in connection with the tax due, or (
  2. b)notifies the Revenue Commissioners in writing that he or she is not a chargeable person in respect of that chargeable period, then, for the purposes of this section, it shall be deemed that no notice was served under subsection
(1)and the person may make a claim for repayment in accordance with section 865 of any excess of tax which may have been paid in respect of the chargeable period.”. Exemption of certain profits or gains arising from cost rental properties 33. The Principal Act is amended by the insertion of the following section after section 222: “222A.
(1)In this section— ‘Act of 2021’ means the Affordable Housing Act 2021 ; ‘cost rental dwelling’ has the same meaning as it has in Part 3 of the Act of 2021; ‘cost rental revocation’ has the same meaning as it has in Part 3 of the Act of 2021; ‘Minister’ means the Minister for Housing, Local Government and Heritage; ‘qualifying cost rental dwelling’ means a cost rental dwelling that is first designated as such by the Minister on or after 8 October 2025; ‘qualifying provider’ means a person chargeable in respect of the relevant profits or gains from a qualifying cost rental dwelling; ‘relevant profits or gains’ means the profits or gains, computed as provided for in section 97
(1), arising from any rent and receipts from a qualifying cost rental dwelling.
(2)Notwithstanding any other provision of this Act— (
  1. a)relevant profits or gains arising to a qualifying provider from qualifying cost rental dwellings which, but for this section, would have been chargeable to tax under Case V of Schedule D, (
  2. b)any deficiencies, computed in accordance with section 97
(1), arising to a qualifying provider in respect of qualifying cost rental dwellings, (
  1. c)any reliefs under Chapter 8 of Part 4 that could be claimed by a qualifying provider in respect of qualifying cost rental dwellings, and (
  2. d)any allowance that could be made to a qualifying provider, in accordance with Part 9, in respect of qualifying cost rental dwellings, shall be disregarded for all purposes of the Corporation Tax Acts.
(3)Notwithstanding subsection
(2), as respects the making of a return of income and self assessment which a chargeable person, within the meaning of Part 41A, is required to deliver under Chapter 3 of that Part— (
  1. a)the provisions of Part 41A shall apply as if a qualifying provider in receipt of relevant profits or gains in any accounting period were, if such person would not otherwise be, a chargeable person (within the meaning of that Part) for that accounting period, (
  2. b)any notice issued to the qualifying provider under section 959N shall be treated as if it had not issued, (
  3. c)section 886 shall apply as if the relevant profits or gains received by the qualifying provider were chargeable to corporation tax, and (
  4. d)the qualifying provider shall state on the return for the chargeable period— (
  5. i)the number of qualifying cost rental dwellings in respect of which the qualifying provider is in receipt of rent and receipts, (
  6. ii)the total amount of rent and receipts from the dwellings referred to in subparagraph (
  7. i)in the chargeable period, and (iii) the profits or gains that would have been subject to corporation tax if subsection
(2)did not apply.
(4)For the purposes of subsection
(3), the relevant profits or gains, deficiencies, reliefs and allowances in respect of qualifying cost rental dwellings shall be computed in accordance with the Corporation Tax Acts as if subsection
(2)had not been enacted.
(5)Where the Minister issues a cost rental revocation— (
  1. a)the Minister shall notify the Revenue Commissioners in writing of the following: (
  2. i)that a cost rental revocation has been issued in respect of the qualifying cost rental dwelling concerned; (
  3. ii)the address of the dwelling referred to in subparagraph (i); (iii) the date on which the cost rental revocation was sealed by the Minister, (
  4. b)subsection
(2)shall not apply to the profits or gains, losses and reliefs arising in respect of the dwelling referred to in paragraph (a)(
  1. i)on or after the date referred to in paragraph (a)(iii), and (
  2. c)where an allowance under Part 9 for any accounting period would have been due but for subsection
(2)(d), the amount due shall be deemed to have been granted.”. Amendment of Schedule 4 to Principal Act (Exemption of Specified Non-Commercial State Sponsored Bodies from Certain Tax Provisions) 34. Schedule 4 to the Principal Act is amended by the insertion of the following paragraph after paragraph 84A: “84B. Property Services Regulatory Authority.”. Amendment of Chapter 2 of Part 29 of Principal Act (scientific and certain other research) 35.
(1)Chapter 2 of Part 29 of the Principal Act is amended— (
  1. a)in section 766, by the insertion of the following subsection after subsection (1A): “(1B) For the purposes of this section and section 766C— (
  2. a)Where expenditure is incurred by a company on emoluments paid to an employee of the company who performs not less than 95 per cent of the duties of his or her employment in the carrying on by the company of research and development activities, 100 per cent of that expenditure shall be treated for the purposes of the definition, in subsection
(1)(a), of ‘expenditure on research and development’, as expenditure incurred by the company wholly and exclusively in the carrying on by it of research and development activities, save where the expenditure is incurred by a company which is resident in the State and where that expenditure— (
  1. i)may be taken into account as an expense in computing income of that company, (
  2. ii)is expenditure in respect of which an allowance for capital expenditure may be made to that company, or (iii) may otherwise be allowed or relieved in relation to that company, for the purposes of tax in a territory other than the State. (
  3. b)In this subsection, ‘emoluments’ and ‘employee’ have the meaning given to them, respectively, by section 983.”, (
  4. b)in section 766A— (
  5. i)in subsection
(1)(a), in the definition of “relevant expenditure”, by the insertion of “or being expenditure of the type referred to in subsection (1A)” after “Part 9”, and (ii) by the insertion of the following subsection after subsection
(1): “(1A) For the purposes of the definition, in subsection
(1)(a), of ‘relevant expenditure’, expenditure incurred by a company on the construction of a qualifying building shall include expenditure incurred by the company on the construction of a laboratory for use in the carrying on of research and development activities but does not include expenditure— (a) to which section 765
(1)(a)(
  1. ii)applies, or (
  2. b)which is incurred on the construction of any part of the laboratory for use as an office or for any purpose ancillary to the purpose of an office.”, (
  3. c)in section 766C— (
  4. i)in subsection
(1), by the substitution of “35 per cent” for “30 per cent”, (ii) in subsection
(2)(a)(ii), by the substitution of “subsection
(7)(a)(i)” for “subsection
(7)(a)”, (iii) in subsection
(6)(a)(i), by the substitution of “€87,500” for “€75,000”, (iv) by the substitution of the following subsection for subsection
(7): “
(7)(a) The company shall specify in respect of each instalment referred to in subsection
(6)whether such amounts, or any portion of such amounts, are to be— (
  1. i)treated as an overpayment of tax, for the purposes of section 960H, or (
  2. ii)paid to the company by the Revenue Commissioners. (
  3. b)Subject to paragraph (c), the company shall make the specification referred to in paragraph (a)— (
  4. i)in respect of the first instalment, in the return referred to in subsection
(9), (
  1. ii)in respect of the second instalment, if any, in the return that the company is required to file under Part 41A in respect of the accounting period (in this paragraph referred to as ‘the first mentioned accounting period’) immediately succeeding the accounting period in respect of which the claim was made, and (iii) in respect of the third instalment, if any, in the return that the company is required to file under Part 41A in respect of the accounting period immediately succeeding the first-mentioned accounting period. (
  2. c)Where, in relation to an accounting period, a company makes a claim in respect of the credit in accordance with subsection
(9)(in this paragraph referred to as ‘the first-mentioned claim’), and a second or third instalment is payable in accordance with subsection
(11)in respect of a claim for the credit made in an earlier accounting period, the company may make the specification referred to in paragraph (
  1. a)in respect of the second or third instalment, or both, as the case may be, on the making of the first mentioned claim.”, (
  2. v)in subsection (7A), by the substitution of “subsection
(7)(a)(i) or paid to the company in accordance with subsection
(7)(a)(ii)” for “subsection
(7)(a) or paid to the company in accordance with subsection
(7)(b)”, (vi) in subsection
(10)(a), by the substitution of “subsection
(7)(a)(i) or paid to the company under subsection
(7)(a)(ii)” for “subsection
(7)(a) or paid to the company under subsection
(7)(b)”, (vii) in subsection
(11)(c), by the substitution of the following subparagraph for subparagraph (i): “(i) where the first-mentioned accounting period is for a period of 12 months and the accounting period (in this subparagraph referred to as ‘the second-mentioned accounting period’) immediately succeeding the first-mentioned accounting period is for a period of 12 months, on the filing of the return that the company is required to file under Part 41A for the second-mentioned accounting period, or”, (viii) in subsection
(13), by the substitution of “subsection
(7)(a)(i)” for “subsection
(7)(a)”, and (ix) in subsection
(15), by the substitution of “subsection
(7)(a)(i) or to be paid under subsection
(7)(a)(ii)” for “subsection
(7)(a) or to be paid under subsection
(7)(b)”, and (
  1. d)in section 766D— (
  2. i)in subsection
(1), by the substitution of “35 per cent” for “30 per cent”, (ii) in subsection
(2)(a)(ii), by the substitution of “subsection
(6)(a)(i)” for “subsection
(6)(a)”, (iii) in subsection (3A)(c)(II), by the substitution of “subsection
(6)(a)(i) or paid to the company in accordance with subsection
(6)(a)(ii)” for “subsection
(6)(a) or paid to the company in accordance with subsection
(6)(b)”, (iv) by the substitution of the following subsection for subsection
(6): “
(6)(a) The company shall specify in respect of each instalment referred to in subsection
(5)whether such amounts, or any portion of such amounts, are to be— (
  1. i)treated as an overpayment of tax, for the purposes of section 960H, or (
  2. ii)paid to the company by the Revenue Commissioners. (
  3. b)Subject to paragraph (c), the company shall make the specification referred to in paragraph (a)— (
  4. i)in respect of the first instalment, in the return referred to in subsection
(8), (
  1. ii)in respect of the second instalment, if any, in the return that the company is required to file under Part 41A in respect of the accounting period (in this paragraph referred to as ‘the first mentioned accounting period’) immediately succeeding the accounting period in respect of which the claim was made, and (iii) in respect of the third instalment, if any, in the return that the company is required to file under Part 41A in respect of the accounting period immediately succeeding the first-mentioned accounting period. (
  2. c)Where, in relation to an accounting period, a company makes a claim in respect of the credit in accordance with subsection
(8)(in this paragraph referred to as ‘the first-mentioned claim’), and a second or third instalment is payable in accordance with subsection
(10)in respect of a claim for the credit made in an earlier accounting period, the company may make the specification referred to in paragraph (
  1. a)in respect of the second or third instalment, or both, as the case may be, on the making of the first mentioned claim.”, (
  2. v)in subsection
(9)(a), by the substitution of “subsection
(6)(a)(i) or paid to the company under subsection
(6)(a)(ii)” for “subsection
(6)(a) or paid to the company under subsection
(6)(b)”, (vi) in subsection
(10)(c), by the substitution of the following subparagraph for subparagraph (i): “(i) where the first-mentioned accounting period is for a period of 12 months and the accounting period (in this subparagraph referred to as ‘the second-mentioned accounting period’) immediately succeeding the first-mentioned accounting period is for a period of 12 months, on the filing of the return that the company is required to file under Part 41A for the second mentioned accounting period, or”, (vii) in subsection
(12), by the substitution of “subsection
(6)(a)(i)” for “subsection
(6)(a)”, and (viii) in subsection
(14), by the substitution of “subsection
(6)(a)(i) or to be paid under subsection
(6)(a)(ii)” for “subsection
(6)(a) or to be paid under subsection
(6)(b)”.
(2)(
  1. a)Paragraph (a), subparagraphs (
  2. i)and (iii) of paragraph (
  3. c)and subparagraph (
  4. i)of paragraph (
  5. d)of subsection
(1)shall apply in respect of any accounting period the specified return date (within the meaning of Part 41A) of which is on or after 23 September 2027. (b) Paragraph (b) of subsection
(1)shall apply on and from the date of the passing of this Act. (
  1. c)Subparagraphs (ii), (iv), (v), (vi), (viii) and (
  2. ix)of paragraph (
  3. c)and subparagraphs (ii), (iii), (iv), (v), (vii) and (viii) of paragraph (
  4. d)of subsection
(1)shall apply in respect of accounting periods ending on or after 31 December 2025. (d) Paragraph (c)(vii) of subsection
(1)shall apply in respect of instalments payable in accordance with section 766C on and from the date of the passing of this Act. (e) Paragraph (d)(vi) of subsection
(1)shall apply in respect of instalments payable in accordance with section 766D on and from the date of the passing of this Act. Taxation of certain foreign body corporates 36. Part 43 of the Principal Act is amended by the insertion of the following section after section 1009: “1009A. Notwithstanding any provision of the Tax Acts or the Capital Gains Tax Acts, as the case may be, a body corporate and each of its members shall be chargeable to tax or capital gains tax, as the case may be, on their respective income, profits or gains on the basis that the body corporate is a partnership and each of its members are partners in a partnership where— (a) the body corporate is incorporated, or formed, under the laws of a jurisdiction other than the State, and (b) having regard to the characteristics of that body corporate and the rights and obligations of each of its members, the body corporate is substantially similar to a partnership formed under the law of the State.”. Life assurance policies and investment funds 37.
(1)The Principal Act is amended— (a) in section 730F
(1)(a)(ii), by the substitution of “38 per cent” for “41 per cent”, (
  1. b)in section 730J(a)(i)(II), by the substitution of “38 per cent” for “41 per cent”, (
  2. c)in section 730K
(1)(a)(ii), by the substitution of “38 per cent” for “41 per cent”, (
  1. d)in section 739D(5A), in the formula in paragraph (b), by the substitution of “(G x 38)” for “(G x 41)”, (
  2. e)in section 739E
(1)— (
  1. i)in paragraph (a)(ii), by the substitution of “38 per cent” for “41 per cent”, and (
  2. ii)in paragraph (b)(ii), by the substitution of “38 per cent” for “41 per cent”, (
  3. f)in section 747D(a)(i)(II), by the substitution of “38 per cent” for “41 per cent”, and (
  4. g)in section 747E
(1)(b)(ii), by the substitution of “38 per cent” for “41 per cent”.
(2)(a) Subsection
(1)(
  1. a)applies and has effect as respects the happening of a chargeable event in relation to a life policy (within the meaning of Chapter 5 of Part 26 of the Principal Act) on or after 1 January 2026. (
  2. b)Subsection
(1)(
  1. b)applies and has effect as respects the receipt by a person of a payment in respect of a foreign life policy (within the meaning of Chapter 6 of Part 26 of the Principal Act) on or after 1 January 2026. (
  2. c)Subsection
(1)(
  1. c)applies and has effect as respects the disposal in whole or in part of a foreign life policy (within the meaning of Chapter 6 of Part 26 of the Principal Act) on or after 1 January 2026. (
  2. d)Subsection
(1)(
  1. d)and (
  2. e)apply and have effect as respects the happening of a chargeable event in relation to an investment undertaking (within the meaning of section 739B
(1)of the Principal Act) on or after 1 January 2026. (e) Subsection
(1)(
  1. f)applies and has effect as respects the receipt by a person of a payment in respect of a material interest in an offshore fund (within the meaning of Chapter 4 of Part 27 of the Principal Act) on or after 1 January 2026. (
  2. f)Subsection
(1)(g) applies and has effect as respects the disposal in whole or in part by a person of a material interest in an offshore fund (within the meaning of Chapter 4 of Part 27 of the Principal Act) on or after 1 January 2026. Amendment of section 731 of Principal Act (chargeable gains accruing to unit trusts) 38.
(1)Section 731 of the Principal Act is amended, in subsection
(5)(a)(i), by the substitution of “(otherwise than by reason of residence, by virtue of section 739
(3)or by virtue of section 739C
(1))” for “(otherwise than by reason of residence or by virtue of section 739
(3))”.
(2)Subsection
(1)shall apply for the year of assessment 2026 and each subsequent year of assessment. Exemption from dividend withholding tax for certain investment limited partnerships 39.
(1)Part 6 of the Principal Act is amended— (a) in section 172A
(1)(a), by the insertion of the following definitions: “ ‘equivalent partnership’ means a partnership which would be an investment limited partnership but for the fact that it is authorised by an EEA state other than the State and is subject to such supervisory and regulatory arrangements in the EEA state by which it is authorised at least equivalent to those applied to an investment limited partnership; ‘investment limited partnership’ means a partnership authorised in accordance with the Investment Limited Partnerships Act 1994 ;”, and (b) in section 172C— (i) in subsection
(2), by the insertion of the following paragraph after paragraph (db): “(dc) subject to subsection
(4), an investment limited partnership or equivalent partnership, as the case may be, where— (
  1. i)the partners of the investment limited partnership or equivalent partnership are beneficially entitled to not less than 51 per cent of the ordinary share capital of the company making the relevant distribution, (
  2. ii)the ordinary share capital of the company making the relevant distribution is an asset of that investment limited partnership or equivalent partnership, and (iii) that investment limited partnership or equivalent partnership has made a declaration, to the company making the relevant distribution, in relation to the relevant distribution in accordance with paragraph 14 of Schedule 2A,”, (
  3. ii)in subsection
(3)— (I) in paragraph (d), by the deletion of “and”, (II) in paragraph (e), by the substitution of “PEPP assets, and” for “PEPP assets,”, and (III) by the insertion of the following paragraph after paragraph (e): “(f) an investment limited partnership or equivalent partnership, as the case may be, which receives a relevant distribution,”, and (iii) in subsection
(4), by the substitution of “paragraph (
  1. bd)or (
  2. dc)of subsection
(2)” for “subsection
(2)(bd)”.
(2)Section 739J of the Principal Act is amended by the insertion of the following subsection after subsection (3A): “(3B) A statement made under subsection
(3)shall be treated as if it satisfies the requirements in respect of the making of a return under section 880, 959I or 959M, as the case may be.”.
(3)Schedule 2A of the Principal Act is amended by the insertion of the following paragraph after paragraph 13: “Declaration to be made by investment limited partnership or equivalent partnership under section 172C
(2)(dc) 14. The declaration referred to in section 172C
(2)(
  1. dc)shall be a declaration in writing to the company making the relevant distribution in relation to the relevant distributions which— (
  2. a)is made by the person (in this paragraph referred to as ‘the declarer’) beneficially entitled to the relevant distributions in respect of which the declaration is made, (
  3. b)is signed by the declarer, (
  4. c)is made in such form as may be prescribed or authorised by the Revenue Commissioners, (
  5. d)declares that, at the time when the declaration is made, the person beneficially entitled to the relevant distributions is an investment limited partnership or equivalent partnership, (
  6. e)contains the name and tax reference number of the investment limited partnership or equivalent partnership, (
  7. f)contains an undertaking by the declarer that, if the person mentioned in subparagraph (
  8. d)ceases to be an excluded person, the declarer will, by notice in writing, advise the company resident in the State in relation to the relevant distributions accordingly, and (
  9. g)contains such other information as the Revenue Commissioners may reasonably require for the purposes of Chapter 8A of Part 6.”.
(4)(a) Subsection
(1)and
(3)shall apply in respect of a relevant distribution (within the meaning of section 172A of the Principal Act) made on or after 1 January 2026. (b) Subsection
(2)shall apply for the year of assessment 2026 and each subsequent year. Amendment to section 835AVB of Principal Act (collective investment scheme) 40.
(1)Section 835AVB of the Principal Act is amended— (a) in subsection
(1)— (
  1. i)by the insertion of the following definitions: “ ‘EEA Agreement’ means the Agreement on the European Economic Area signed at Oporto on 2 May 1992, as adjusted by all subsequent amendments to that Agreement; ‘EEA state’ means a state which is a contracting party to the EEA Agreement; ‘foreign tax’, in relation to a relevant territory, means a tax which— (
  2. a)corresponds to corporation tax in the State, (
  3. b)generally applies to income, profits and gains arising to a company that is resident for the purposes of tax in that territory, and (
  4. c)is imposed at a nominal rate greater than zero per cent; ‘investment limited partnership’ means a partnership authorised in accordance with the Investment Limited Partnerships Act 1994 ; ‘listed territory’ has the same meaning as it has in section 835YA; ‘relevant company’, in relation to an investment limited partnership, means a company— (
  5. a)which is a direct or indirect asset of the investment limited partnership, (
  6. b)in which the partners of the investment limited partnership are beneficially entitled, directly or indirectly, to not less than 95 per cent of its ordinary share capital, (
  7. c)whose business consists of the holding, directly or indirectly, of a diversified portfolio of assets, and (
  8. d)which is— (
  9. i)resident in the State, or (
  10. ii)by virtue of the law of a relevant territory, is— (I) resident for the purposes of foreign tax in the relevant territory, and (II) not generally exempt from foreign tax; ‘relevant territory’ means— (
  11. a)an EEA state, other than the State, (
  12. b)not being such an EEA state, a territory with the government of which arrangements having the force of law by virtue of section 826
(1)have been made, or (
  1. c)not being a territory referred to in paragraph (
  2. a)or (b), a territory with the government of which arrangements have been made which on completion of the procedures set out in section 826
(1)will have the force of law, but does not include a listed territory;”, and (
  1. ii)in paragraph (
  2. b)of the definition of “relevant investment undertaking”, by the deletion of “, within the meaning of section 739J”, (
  3. b)in subsection
(4)(a), by the substitution of “20 per cent” for “10 per cent”, and (c) by the insertion of the following subsection after subsection
(4): “(4A) In the case of an investment limited partnership, for the purposes of subsection
(4)(a)— (
  1. a)a relevant company shall not be considered to be an issuer of securities to the investment limited partnership, and (
  2. b)an investment limited partnership shall be deemed to hold directly any securities held by a relevant company.”.
(2)Subsection
(1)shall apply for the year of assessment 2026 and each subsequent year. Amendments relating to group payments 41.
(1)The Principal Act is amended— (
  1. a)in section 410— (
  2. i)in subsection
(1)(a)— (I) by the substitution of the following definition for the definition of “tax”: “ ‘tax’, in relation to a relevant territory other than the State, means any tax imposed in the relevant territory which corresponds to corporation tax in the State;”, and (II) by the insertion of the following definition: “ ‘relevant territory’ means— (i) a relevant Member State, (ii) not being a territory referred to in subparagraph (i), a territory with the government of which arrangements having the force of law by virtue of section 826
(1)have been made, or (iii) not being a territory referred to in subparagraph (i) or (ii), a territory with the government of which arrangements have been made which on completion of the procedures set out in section 826
(1)will have the force of law;”, (ii) in subsection
(1)(b)— (I) in subparagraph (i), by the substitution of “relevant territory” for “relevant Member State”, and (II) by the substitution of the following subparagraph for subparagraph (ii): “(ii) references to— (I) a company resident in a relevant Member State shall be construed as references to a company which, by virtue of the law of a relevant Member State, is resident for the purposes of tax in such a relevant Member State, and (II) a company resident in a relevant territory shall be construed as references to a company which, by virtue of the law of a relevant territory, is resident for the purposes of tax in such a relevant territory.”, (iii) in subsection
(3)(a), by the substitution of “relevant territory” for “relevant Member State”, and (iv) in subsection
(4)(a)(i), by the substitution of “relevant territory” for “relevant Member State”, and (b) in section 243
(5)(c), by the substitution of “section 242A, 267I or 410
(4)” for “section 242A or 267I”.
(2)Subsection
(1)shall apply to payments to which section 410 of the Principal Act applies made on or after the date of the passing of this Act. Chapter 5 Corporation Tax Enhanced deduction for eligible construction expenditure 42. The Principal Act is amended by the insertion of the following section after section 81D: “81E.
(1)In this section— ‘apartment’ means a separate and self-contained dwelling in a qualifying apartment block— (
  1. a)that has sleeping facilities, bathroom facilities and cooking facilities within it for the exclusive use of the occupant of the dwelling concerned, and (
  2. b)other than where the dwelling is situated on the ground floor of a multi-storey building, access to the dwelling is grouped or in common with other separate and self-contained dwellings; ‘certificate of compliance on completion’, ‘commencement notice’, ‘local authority’, ‘planning permission’ and ‘planning permission period’ have the same meaning, respectively, as they have in section 653A
(1); ‘completed development’ means a qualifying apartment block, in respect of which— (
  1. a)planning permission has been granted which includes permission for not fewer than 10 new apartments in the qualifying apartment block, (
  2. b)a relevant commencement notice is lodged with the relevant local authority on or after 8 October 2025 but not later than 31 December 2030, and (
  3. c)on or before the expiry of the planning permission period relating to it— (
  4. i)all works required to ensure that all apartments in the qualifying apartment block are suitable for occupation as a dwelling have been completed, and (
  5. ii)a relevant certificate of compliance on completion is lodged with the relevant local authority; ‘construction operations’ and ‘excepted trade’ have the same meaning, respectively, as they have in section 21A; ‘eligible expenditure’, in relation to a completed development, means, subject to subsection
(8), expenditure incurred by a relevant person in connection with construction operations carried out in respect of the completed development, being expenditure which is incurred up to the relevant date, excluding— (a) any capital expenditure so incurred, and (b) ineligible expenditure; ‘enhanced deduction’ has the meaning given to it by subsection
(4); ‘ineligible expenditure’, in relation to a completed development, means any expenditure incurred by a relevant person in respect of the completed development in respect of any or all of the following: (
  1. a)financing costs; (
  2. b)insurance costs; (
  3. c)professional and legal fees; (
  4. d)sales and marketing costs; (
  5. e)taxes, duties, levies or charges under the care and management of the Revenue Commissioners; (
  6. f)the acquisition of, or rights in or over, any land; (
  7. g)levies, fees, charges or contributions imposed by, or under, any enactment in respect of the completed development concerned, however described in the relevant enactment, including any— (
  8. i)development contributions, (
  9. ii)utility connection charges, (iii) environmental levies, (
  10. iv)planning application fees, (
  11. v)building control fees, or (
  12. vi)building energy rating fees; ‘land’ includes any interest in land; ‘material change’ shall be construed in accordance with subsection
(2); ‘property developer’ means a company carrying on a relevant property development trade; ‘qualifying apartment block’ means a building that— (
  1. a)is a multi-storey building, (
  2. b)is principally comprised of not fewer than 10 apartments, and (
  3. c)is— (
  4. i)a newly erected building, or (
  5. ii)not being a building referred to in subparagraph (i), a building that meets the requirements of paragraphs (
  6. a)and (
  7. b)as a result of a material change, and includes an area of land for occupation and enjoyment by its oc

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