IE-2024-43 Finance Act 2024 IE

in subsection (3), by the substitution of 27,382 for 25,760, and

by the substitution of the following for Part 1 of the Table to that section:

Part of aggregate income

(1)

Rate of universal social charge

(2)

The first 12,012

0.5 per cent

The next 15,370

2 per cent

The next 42,662

3 per cent

The remainder

8 per cent

in section 15

in section 461

in section 462B(3), by the substitution of 1,900 for 1,750,

in section 465(1), by the substitution of 3,800 for 3,500,

in section 466(2), by the substitution of 305 for 245,

in section 466A(2), by the substitution of 1,950 for 1,800,

in section 468(2)

in section 472(4), by the substitution of 2,000 for 1,875 in each place where it occurs, and

in section 472AB

in subsection (1), in the definition of specified amount

in subsection (13)

in subsection (1)

in subsection (2), by the substitution of a qualifying period referred to in paragraph (a) or (b), as the case may be, of the definition of that term in subsection (1) for the qualifying period,

in subsection (4)(a), by the substitution of For the purposes of this section, in respect of a claim under subsection (2) for the year of assessment 2023, for For the purposes of this section,,

by the insertion of the following subsection after subsection (4):

(4A) (a) For the purposes of this section, in respect of a claim under subsection (2) for the year of assessment 2024, relievable interest, in relation to an individual, shall be an amount determined by the formula

where

A is the amount of qualifying interest for the year of assessment 2024, and

B is the amount of qualifying interest for the year of assessment 2022.

(b) Where qualifying interest paid for a year of assessment referred to in paragraph (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 (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 (a) shall

in subsection (5), by the substitution of Where, for the year of assessment 2023 for Where, for a year of assessment,

by the insertion of the following subsection after subsection (5):

(5A) Where, for the year of assessment 2024, qualifying interest referred to in subsection (4A) is for a period of less than 365 days, then

(a) where

the upper limit shall be determined by the formula

or

(b) where the number of days in the year of assessment to which A in the formula in subsection (4A) relates is less than 365 and the number of days in the year of assessment to which B in the formula in subsection (4A) relates is less than 365, then, the upper limit shall be determined by the formula

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.,

in subsection (7)(a), by the substitution of a qualifying period referred to in paragraph (a) or (b), as the case may be, of the definition of that term in subsection (1) for the qualifying period,

in subsection (8)(a), by the substitution of the calendar year 2023 or 2024, as the case may be, for the calendar year 2023,

in subsection (9)(b), by the substitution of subsection (4) or (4A), as the case may be for subsection (4), and

in subsection (11)(e), by the substitution of the following subparagraphs for subparagraphs (i) and (ii):

in subsection (1)

in subsection (5A), by the substitution of 31 December 2029 for 31 December 2025,

in subsection (8)(b), by the substitution of 2029 for 2025,

in subsection (16)(a), in subparagraphs (ii) and (iii), by the substitution of 31 December 2029 for 31 December 2025, and

in subsection (25), by the substitution of 31 December 2029 for 31 December 2025.

in subsection (1), by the substitution of the following definition for the definition of qualifying incentive:

qualifying incentive means a relevant incentive that is the first, second, third, fourth or fifth relevant incentive given to an employee in a year of assessment where

(a) in the case of a first relevant incentive, the value does not exceed 1,500,

(b) in the case of a second relevant incentive, the cumulative value of the first and second relevant incentives does not exceed 1,500,

(c) in the case of a third relevant incentive, the cumulative value of the first, second and third relevant incentives does not exceed 1,500,

(d) in the case of a fourth relevant incentive, the cumulative value of the first, second, third and fourth relevant incentives does not exceed 1,500, and

(e) in the case of a fifth relevant incentive, the cumulative value of the first, second, third, fourth and fifth relevant incentives does not exceed 1,500;,

and

by the insertion of the following subsection after subsection (2):

(3) This section shall cease to have effect for the year of assessment 2030 and subsequent years of assessment..

in paragraph (aa)(iii), by the substitution of subject to paragraph (ab), 35,000 for 35,000,

in paragraph (ab)

in paragraph (ba), by the substitution of years of assessment 2023, 2024 and 2025 for years of assessment 2023 and 2024.

in subparagraph (vii)(III), by the substitution of subject to subparagraph (viii), 35,000 for 35,000,

in subparagraph (viii),

in section 118, by the substitution of the following subsection for subsection (5):

(5) Subsection (1) shall not apply to expense incurred by the body corporate in or in connection with the provision for a director or employee, or for the directors or employees spouse, civil partner, children or dependants, or for the children of the directors or employees civil partner, of any

(a) pension, annuity, lump sum or gratuity,

(b) contribution to a Personal Retirement Savings Account (within the meaning of Chapter 2A of Part 30), provided that contribution does not exceed the employer limit (within the meaning of section 787A),

(c) contribution to a PEPP (within the meaning of Chapter 2D of Part 30), provided that contribution does not exceed the employer limit (within the meaning of section 787V), or

(d) other like benefit to be given on the death or retirement of the director or employee.,

in section 787A(1), by the insertion of the following definitions:

emoluments has the same meaning as in Chapter 4 of Part 42;

employer limit, in relation to a contribution by an employer to an employees PRSA, means an amount not exceeding

(a) 100 per cent of the employees emoluments in the year of assessment from that employer, or

(b) where the employees emoluments for the year of assessment from that employer are lower than that employees emoluments for the previous year of assessment from that employer by virtue of

100 per cent of the employees emoluments from that employer in the previous year of assessment;,

in section 787E, by the insertion of the following subsection after subsection (1):

(1A) Where an employer makes a contribution to an employees PRSA and the total of such contributions exceeds the employer limit, the sum of those contributions made, less the employer limit, shall be chargeable to tax as income of the employee, in accordance with section 118(1).,

in section 787J

in section 787V(1), by the insertion of the following definitions:

emoluments has the same meaning as in Chapter 4 of Part 42;

employer limit, in relation to a contribution by an employer to an employees PEPP, means an amount not exceeding

(a) 100 per cent of the employees emoluments in the year of assessment from that employer, or

(b) where the employees emoluments for the year of assessment from that employer are lower than that employees emoluments for the previous year of assessment from that employer by virtue of

100 per cent of the employees emoluments in the previous year of assessment from that employer;,

in section 787Z by the insertion of the following subsection after subsection (1):

(1A) Where an employer makes a contribution to an employees PEPP and the total of such contributions exceeds the employer limit, the sum of those contributions made, less the employer limit, shall be chargeable to tax as income of the employee, in accordance with section 118(1).,

and

in section 787AD

in section 787O(1)

in section 790AA(1)(a), by the substitution of the following definition for the definition of standard chargeable amount:

standard chargeable amount means 500,000 less the tax free amount;,

and

in Schedule 23B

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 meaning of Chapter 2E of Part 30).,

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.,

in section 246(3)

in section 256(1), in the definition of relevant deposit

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),

in section 706(3), by the insertion of the following paragraph after paragraph (e):

(f) any contract with an AE provider scheme (within the meaning of the Automatic Enrolment Retirement Savings System Act 2024);,

in section 739D(6), by the insertion of the following paragraph after paragraph (kc):

(kd) is a participant within the meaning of the Automatic Enrolment Retirement Savings System Act 2024, the units are held by the Authority within the meaning of that Act on behalf of the participant and the Authority has made a declaration to that effect to the investment undertaking,,

in section 787O(1)

in section 790AA(1)(a), in the definition of relevant pension arrangement

in paragraph (g), by the substitution of that Chapter, or for that Chapter;, and

by the insertion of the following paragraph after paragraph (g):

(h) an AE provider scheme within the meaning of the Automatic Enrolment Retirement Savings System Act 2024;.

in paragraph 3(c)

in paragraph 3A, by the substitution of the following subparagraph for subparagraph (a):

(a) each restructured or amalgamated body held an authorisation as at the date of the initiation of the process of re-organisation, and,

and

in paragraph 3B, by the substitution of the following subparagraph for subparagraph (a):

(a) the restructured body held an authorisation as at the date of the initiation of the process of re-organisation, and.

in section 207

in section 208

in section 208A, by the insertion of the following subsection after subsection (4):

(4A) Where a person or trust has received a determination in accordance with subsection (3) and has income in the State of a kind referred to in section 207 or 208, as the case may be, the Revenue Commissioners, or such officer of the Revenue Commissioners as they may authorise in that behalf, may allow an extension of the cut-off point referred to in section 207(1A) or section 208(4), as appropriate, subject to the Revenue Commissioners or that officer, as the case may be, being satisfied that the person or trust is in the process of applying the income concerned to charitable purposes..

in subsection (1)

in subsection (3)

in subsection (1), in the definition of appropriate certificate, by the substitution of subsection (9)(a)(i) or (11)(a)(i), as the case may be for subsection (9),

in subsection (2), by the substitution of subsection (9)(a)(i) or (11)(a)(i), as the case may be for subsection (9),

in subsection (3)(b), by the substitution of Subsections (5) to (8) of section 1094 shall apply for Subsections (5) to (9) of section 1094 shall apply,

in subsection (5)

by the substitution of the following subsection for subsection (9):

(9) (a) Where a relevant donation, other than a relevant donation to which subsection (18) applies, is made by an individual who is a chargeable person (within the meaning of Part 41A) for the relevant year of assessment, then the individual shall elect that subparagraph (i) or (ii) shall apply to the donation as follows:

(b) For the purposes of paragraph (a)(i), any such deduction or set-off shall not be taken into account in determining the net relevant earnings (within the meaning of section 787) of the individual or, as the case may be, the individuals spouse or civil partner for the relevant year of assessment.

(c) The Revenue Commissioners may make regulations for the purposes of setting down the conditions under which an individual shall make the election referred to in paragraph (a).

(d) For the purposes of paragraph (a)(i), an individual shall make a claim with the return required to be delivered by the individual under Chapter 3 of Part 41A for the relevant year of assessment.

(e) For the purposes of applying the provisions of this subsection, the repayment referred to in paragraph (a)(ii) shall not be made to an approved sports body until on or after 1 December in the year following the year in which the relevant donation was made..

by the deletion of subsection (10),

by the substitution of the following subsection for subsection (11):

(11) (a) Where a relevant donation, other than a relevant donation to which subsection (18) applies, is made by an individual who is not an individual referred to in subsection (9), then the individual shall elect that subparagraph (i) or (ii) shall apply:

(b) For the purposes of paragraph (a)(i), any such deduction or set-off shall not be taken into account in determining the net relevant earnings (within the meaning of section 787) of the individual or, as the case may be, the individuals spouse or civil partner for the relevant year of assessment.

(c) The Revenue Commissioners may make regulations for the purposes of setting down the conditions under which an individual shall make the election referred to in paragraph (a).

(d) For the purposes of paragraph (a)(i), an individual shall make a claim through such electronic means as the Revenue Commissioners make available, providing

(e) For the purposes of applying the provisions of this subsection, the repayment referred to in paragraph (a)(ii) shall not be made to an approved sports body until on or after 1 December in the year following the year in which the relevant donation was made.,

by the substitution of the following for subsection (17):

(17) An approved sports body shall not be required to give a receipt under subsection (16) to a donor in respect of a relevant donation to which subsection (18) applies.,

and

in subsection (19), by the substitution of neither section 235(2) nor 235A(2) shall apply for section 235(2) shall not apply.

by the deletion of paragraphs 40, 92, 111, 128 and 180,

by the substitution of the following paragraph for paragraph 140:

140. Personal Injuries Resolution Board.,

and

by the insertion of the following paragraphs after paragraph 214:

215. Maritime Area Regulatory Authority.

216. An Rialla Agraibhia.

217. An Ghnomhaireacht um Fhorigean Baile, Gnasach agus Inscnebhunaithe..

by the insertion of the following subsection after subsection (1):

(1A) For the purposes of a charge to tax on any income, profits or gains from an employment for the year of assessment preceding a year of assessment (in this section referred to, respectively, as the previous year of assessment and the current year of assessment), subsection (2A) shall apply in relation to

(a) an individual, not being an individual to whom subsection (1)(a)(i) applies, who

or

(b) an individual, not being an individual to whom subsection (1)(a)(ii) applies, who

by the insertion of the following subsection after subsection (2):

(2A) (a) An individual to whom paragraph (a) of subsection (1A) applies shall be deemed to be resident in the State for the previous year of assessment only from the date of his or her arrival in the State.

(b) An individual to whom paragraph (b) of subsection (1A) applies shall be deemed to be resident in the State for the previous year of assessment only up to and including the date of his or her leaving the State.,

and

by the insertion of the following subsection after subsection (3):

(4) Subsection (1A) shall apply in respect of the year of assessment 2026 and each subsequent year of assessment..

by the insertion of the following section after section 205B:

205C. (1) In this section

Act of 2019 means the CervicalCheck Tribunal Act 2019;

appropriate person has the same meaning as it has in section 2 of the Act of 2019;

relevant payment means any of the following:

(a) a payment made pursuant to the CervicalCheck non-disclosure ex gratia Scheme (that is to say the scheme administered, under that title, by the Minister for Health in furtherance of a decision of the Government of 11 March 2019);

(b) a payment made pursuant to the Act of 2019;

(c) a payment to an appropriate person in respect of compensation following the institution by or on behalf of a relevant woman of a civil action for damages in respect of personal injury, but excluding any compensation to an appropriate person other than a relevant woman, for mental distress resulting from the relevant womans death;

relevant woman has the same meaning as it has in section 2 of the Act of 2019.

(2) Income that

(a) consists of a relevant payment made to an appropriate person, or

(b) arises to a relevant woman from the investment in whole or in part of a relevant payment or of the income derived from such a payment, being income consisting of dividends or other income which but for this section would be chargeable to tax under Schedule C or under Case III, IV (by virtue of section 59, 745 or 747E) or V of Schedule D or under Schedule F,

shall be exempt from income tax and shall not be reckoned in computing total income for the purposes of the Income Tax Acts.

(3) Gains that accrue to a relevant woman, from the disposal of

(a) assets acquired with a relevant payment,

(b) assets acquired with income exempted from income tax under subsection (2)(b), or

(c) assets acquired directly or indirectly with the proceeds from the disposal of assets referred to in paragraph (a) or (b),

shall not be chargeable gains for the purposes of the Capital Gains Tax Acts.

(4) For the purposes of computing whether by virtue of this section a gain is, in whole or in part, a chargeable gain, or whether income is, in whole or in part, exempt from income tax, all such apportionments shall be made as are, in the circumstances, just and reasonable.

(5) (a) Notwithstanding any limitation in section 865(4) on the time within which a claim for a repayment of tax is required to be made, where this section applies for any of the years of assessment 2008 to 2020 (both years inclusive) the appropriate person shall, on the making of a claim in that behalf, on or before 31 December 2025, be entitled to claim repayment of any amount in respect of income or gains to which this section applies.

Section 865(6) shall not prevent the Revenue Commissioners from repaying an amount of tax as a consequence of a claim made under this section where a valid claim for a repayment of tax (within the meaning of section 865(1)(b)) has been made.,

(b) in section 256(1), by the substitution of the following definition for the definition of relevant amount:

relevant amount means any amount of

(a) income referred to in section 205A(2), income that consists of a payment made to a relevant person (within the meaning of section 205B(1)) under section 32(1)(a) of the Mother and Baby Institutions Payment Scheme Act 2023 or income referred to in section 205C(2)(b), and

(b) gains referred to in section 205A(3), 205B(3) or 205C(3);,

in section 267(3), by the substitution of section 205A(2), 205B(2) or 205C(2) for section 205A(2) or section 205B(2),

in section 613(1)

(i) in paragraph (e), by the substitution of applies; for applies., and

(ii) by the insertion of the following paragraph after paragraph (e):

(f) any payment to which section 205C applies.,

in section 730GA, by the substitution of 205A, 205B or 205C for 205A or 205B, and

in section 739G(2)(j), by the substitution of 205A, 205B or 205C for 205A or 205B.

(a) Subsection (1) shall be deemed to have come into operation on 1 September 2008.

Subsection (2) shall be deemed to have come into operation on 11 March 2019.

Where a payment referred to in section 82(1)(bc) of the Capital Acquisitions Tax Consolidation Act 2003 (inserted by subsection (2)) was made at any time in the year of assessment 2019 or 2020, subsection (3) of section 57 of that Act shall apply as if the reference in that subsection to the making of a valid claim within 4 years commencing on 31 December in the year in which that tax was due to be paid as provided for in paragraph (a) of that subsection were a reference to the making of a valid claim within 4 years commencing on 31 December 2021.

in section 380L

in section 380M

the provision of a vehicle, or

the hiring of a vehicle, except where, prior to that date

in section 216F

in section 486C

in subsection (1), by the insertion of the following definitions:

Revenue officer means an officer of the Revenue Commissioners;

total Case V income, in relation to a person chargeable for a year of assessment, means the total amount of Case V income on which the person chargeable is assessed to income tax after deducting any allowance made in accordance with Part 9 in charging the income under Case V of Schedule D and relief for losses under section 384;,

by the substitution of the following subsection for subsection (2):

(2) In relation to a year of assessment, a person chargeable shall be entitled to a tax credit of the lowest of

(a) in respect of the year of assessment 2024

(b) in respect of the year of assessment 2025

(c) in respect of each of the years of assessment 2026 and 2027

by the insertion of the following subsection after subsection (4):

(4A) For the purposes of subsection (4)(a), a person chargeable shall not cease to be a person chargeable in respect of any qualifying premises that was owned by that person during the first year of assessment by reason only of the death of the person chargeable during a relevant year of assessment.,

and

by the substitution of the following subsection for subsection (5):

(5) (a) Where subsection (4) applies in respect of a relevant year of assessment, a Revenue officer shall make or amend an assessment for each year of assessment in which a tax credit under this section was claimed by the person chargeable for the purposes of the amount of the credit claimed by the person chargeable being repaid.

(b) Any additional tax payable by reason of an assessment made or amended in accordance with paragraph (a) shall be due and payable on the same date as the tax due under the assessment for the year of assessment during which the cessation referred to in subsection (4)(a) or the letting referred to in subsection (4)(b), as the case may be, occurred..

in section 489

in section 496(5)

in section 502

in section 504

in section 507

in section 508(1)(a), by the substitution of the following subparagraph for subparagraph (i):

(i) 140,000 in respect of which relief is available under section 507, or,

in section 508A, by the substitution of the following subsection for subsection (4):

(4) A qualifying company may not issue a statement of qualification in respect of a qualifying investment after 31 December in the year of assessment following the year of assessment in which the shares were issued.,

in section 508C, by the substitution of the following subsection for subsection (4):

(4) A qualifying company may not issue a statement of qualification (SURE) in respect of a relevant investment after 31 December in the year of assessment following the year of assessment in which the shares were issued.,

in section 508Q, by the substitution of the following subsection for subsection (2):

(2) Where subsection (1) applies, the conversion of the loan into eligible shares shall, notwithstanding any other provision of this Part, be treated as the making of a relevant investment by the specified individual on the date of the conversion of the loan into eligible shares provided that the business plan (within the meaning of section 493) on which the relevant investment is based was prepared in advance of the loan.,

in section 508W(1)(a)

in section 508Z

in section 666(4)

in section 667B(5)(b), by the substitution of 31 December 2027 for 31 December 2024, and

in section 667C

(a) Subsection (1) shall apply to companies whose shares are admitted to trading on a regulated market or a multilateral trading facility in an EEA state on or after 1 January 2025.

In this subsection, regulated market, multilateral trading facility and EEA state, have the meaning given to them, respectively, by section 81D (inserted by subsection (1)) of the Principal Act.

in Schedule 4

in Part 1 of Schedule 15, by the insertion of the following paragraph after paragraph 50:

51. Inland Fisheries Ireland..

in section 288

in section 299

in section 403

in section 404

in section 485C, by the deletion of subsection (1B), and

in Schedule 25B, by the deletion of the entries at Reference Numbers 15C and 15D and the matters set opposite those reference numbers.

in subsection (1)

in subsection (6), by the deletion of , that is resident or situated in a different territory,.

in subsection (1)

by the insertion of the following subsection after subsection (3):

(4) (a) Subject to paragraph (b), where a disallowable amount or total spare capacity is calculated in a currency (in this paragraph referred to as the first-mentioned currency) other than the currency of the State, and is carried forward to a subsequent accounting period as

the disallowable amount or total spare capacity carried forward, as the case may be, shall be expressed in the first-mentioned currency for the purposes of the calculations required under this Part.

(b) Where in an accounting period there is a change in the currency (in this paragraph referred to as the old currency) in which a company calculates interest equivalent, or a portion thereof, and the company calculates interest equivalent or a portion thereof in another currency (in this paragraph referred to as the new currency), the amount, if any, carried forward into that accounting period as

shall be expressed in terms of the new currency for the purposes of the calculations required under this Part by reference to the average representative rate of exchange of the old currency for the new currency in the accounting period in which the deemed borrowing cost or total spare capacity, as the case may be, arose.

(c) In this subsection, representative rate of exchange has the same meaning as in section 402..

in subsection (1)

by the insertion of the following subsection after subsection (1B):

(1C) (a) Where a producer company expects a film to be a lower budget film, the producer company, in making its application under subsection (1A), may apply for the certificate mentioned in that subsection to specify, in addition to that mentioned in that subsection, that an increased film corporation tax credit (in this section referred to as the enhanced credit for lower budget film) may apply as provided for in paragraph (c).

(b) In considering whether, in the certification applied for, he or she should specify that the enhanced credit for lower budget film may apply, the Minister, in accordance with regulations made under subsection (2E), shall have regard to whether the film is expected to satisfy the criteria set out in paragraphs (a) to (c) of the definition of lower budget film in subsection (1).

(c) Where

then, the producer company shall

in subsection (2)

in subsection (2E), by the insertion of

in Chapter 2 of Part 35, by the insertion of the following section after section 831A:

Participation exemption for certain foreign distributions

831B. (1) In this section

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 territory other than the State, means a tax which

(a) corresponds to corporation tax in the State,

(b) generally applies to income, profits and gains arising to a company that is resident for the purposes of tax in that territory, and

(c) is imposed at a nominal rate greater than zero per cent;

listed territory has the same meaning as it has in section 835YA subject to the modification that references to an accounting period beginning shall be read as references to the making of a distribution;

parent company, in relation to a relevant subsidiary, means a company that holds a qualifying participation in the relevant subsidiary and

(a) is resident in the State, or

(b) not being resident in the State

qualifying participation shall be construed in accordance with subsection (2);

reference period, in relation to a relevant distribution, means the period of 5 years immediately before the date on which the relevant distribution is made;

relevant distribution means a distribution, or that part of a distribution, that

(a) constitutes income in the hands of the recipient for the purposes of corporation tax, and

(b) is made by a relevant subsidiary in respect of the relevant subsidiarys share capital

but, without prejudice to the generality of paragraphs (a) and (b), does not include

(I) a distribution, or that part of a distribution, that has been, or may be, deducted for the purposes of tax in any territory outside the State under the law of that territory,

(II) a distribution in a winding up,

(III) any interest or other income from debt claims providing rights to participate in a companys profits (within the meaning of section 21B(1)(a)),

(IV) any amount considered to be interest equivalent (within the meaning of section 835AY), or

(V) any dividend paid or other distribution made by an offshore fund as construed in accordance with section 743;

relevant period, in relation to a relevant distribution, means the period

(a) beginning on the date

whichever is the later, and

(b) ending on the date on which the relevant distribution is made;

relevant subsidiary, in relation to a relevant distribution, means a company that

(a) is, on the date on which it makes the relevant distribution and was, throughout the relevant period

(b) did not, at any time during the reference period, acquire

where the business concerned was previously carried on by another company that was not, by virtue of the law of a relevant territory, resident for the purposes of foreign tax in a relevant territory

and

(c) was not formed through a merger at any time during the reference period, where a party to the merger was another company that was not, by virtue of the law of a relevant territory, resident for the purposes of foreign tax in a relevant territory

relevant territory means

(a) an EEA state other than the State,

(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

(c) not being a territory referred to in paragraph (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.

(2) (a) For the purposes of this section, a company shall be regarded as holding a qualifying participation in a relevant subsidiary where the company directly or indirectly owns ordinary share capital in the relevant subsidiary, by virtue of which the company

(b) For the purposes of paragraph (a)

(3) Where in an accounting period

(a) a relevant subsidiary makes a distribution to a parent company of the relevant subsidiary that is, or part of which is, a relevant distribution, and

(b) the parent company would, but for this section, be chargeable to corporation tax in respect of the relevant distribution under

then, subject to subsections (5) to (8), and except where otherwise provided by the Corporation Tax Acts, corporation tax shall not be chargeable on the relevant distribution and the relevant distribution shall not be taken into account in computing income for corporation tax.

(4) Without prejudice to the generality of any other provision of the Tax Acts, where in any case a parent company is not chargeable to corporation tax on a relevant distribution by virtue of this section, that parent company shall not be entitled to a deduction, reduction, credit or other relief for tax paid under the laws of a relevant territory in respect of that relevant distribution.

(5) Subsection (3) shall apply only

(a) where the parent company holds a qualifying participation in the relevant subsidiary for an uninterrupted period of not less than 12 months, being a period during which the relevant distribution is made, and

(b) if the relevant distribution is made by the relevant subsidiary in respect of the relevant subsidiarys share capital out of the assets of the relevant subsidiary, where any gain on the disposal of that share capital by the parent company on the date on which the relevant distribution is made would not be a chargeable gain in accordance with section 626B.

(6) Subsection (3) shall not apply to a relevant distribution made to

(a) an assurance company where the relevant distribution is taxable in accordance with the provisions of Chapters 1 and 3 of Part 26, or

(b) an undertaking for collective investment (within the meaning of section 738) which is a company.

(7) (a) Subsection (3) shall not apply to a relevant distribution which arises in respect of an arrangement, or part of an arrangement, which

(b) For the purposes of paragraph (a)(ii), an arrangement, or part of an arrangement, as the case may be, shall be regarded as not genuine to the extent that it is not put into place for valid commercial reasons which reflect economic reality.

(8) (a) Subsection (3) shall not apply in respect of a relevant distribution made by a relevant subsidiary to a parent company unless the parent company makes a relevant claim for the accounting period in which the relevant distribution is made.

(b) In this subsection, relevant claim, in relation to an accounting period, means a claim made by a parent company in respect of all the relevant distributions made to that parent company in the accounting period by the relevant subsidiaries in respect of which that parent company holds a qualifying participation.

(c) A relevant claim for an accounting period shall be made in the return required to be delivered under Part 41A in respect of the accounting period.,

in section 129A, by the insertion of the following subsection after subsection (5):

(6) Subsection (2) shall not apply to such amount of a distribution as is paid out of profits arising before the paying company became resident in the State, where, if the distribution had been paid on the last date before the date the paying company became resident in the State (or the last such date where there was more than one date), corporation tax would not have been chargeable on the distribution under section 831B if a relevant claim under subsection (8) of section 831B had been made under that section.,

in section 753C(4), by the substitution of section 129A, section 138 or section 831B for section 129A or section 138,

in section 835E(2)(b)(ii)(II), by the substitution of section 129 or 831B for section 129, and

in section 835Q(4), by the substitution of the following paragraph for paragraph (c):

in subsection (1)(a)

in subsection (6)

in Part 19, by the insertion of the following Chapter after section 600A:

Interpretation

600B. In this Chapter

accounting period shall be determined in accordance with section 27;

arrangement includes any agreement, understanding, scheme, transaction or series of transactions (whether enforceable or not);

associate has the same meaning in relation to a person as it has by virtue of subsection (3) of section 433 in relation to a participator;

authorised officer means an officer of the Revenue Commissioners authorised under section 600Q(1);

business plan has the same meaning as in section 493;

certificate of going concern has the meaning given to it by section 600F(3);

certificate of commercial innovation has the meaning given to it by section 600F(4);

certificates of qualification means

(a) a certificate of going concern, and

(b) a certificate of commercial innovation;

control shall be construed in accordance with subsections (2) to (6) of section 432;

date of investment means the date of the issue of the eligible shares;

director shall be construed in accordance with section 433(4);

EEA state has the same meaning as in section 489;

employee has the same meaning as in section 983;

enterprise has the same meaning as in Annex I of the General Block Exemption Regulation;

eligible shares shall be construed in accordance with section 494;

expansion risk finance investment has the same meaning as in section 493;

follow-on risk finance investment has the same meaning as in section 493;

General Block Exemption Regulation has the same meaning as in Part 16;

innovative enterprise has the meaning given to it by Article 2(80) of the General Block Exemption Regulation;

linked businesses has the same meaning as in Part 16;

partner businesses has the same meaning as in Part 16;

partnership agreement means any valid written agreement of the partners governed by the law of the State and subject to the exclusive jurisdiction of the courts of the State as to the affairs of a partnership and the conduct of its business as may be amended, supplemented or restated from time to time;

qualifying company shall be construed in accordance with section 600C;

qualifying investment shall be construed in accordance with section 600J;

qualifying investor shall be construed in accordance with section 600H;

qualifying partnership shall be construed in accordance with section 600N;

qualifying subsidiary shall be construed in accordance with section 600D;

relevant trading activities has the same meaning as in Part 16;

relief group means a company, its partner businesses and linked businesses, taken together, and includes any relief group of which a company is a member and any company that was, at any time, a member of a relief group with a qualifying company or its qualifying subsidiaries;

SME has the same meaning as in Part 16;

undertaking in difficulty has the same meaning as in the General Block Exemption Regulation;

unlisted has the same meaning as in Part 16.

Qualifying company

600C. For the purposes of this Chapter, a company shall be a qualifying company if it holds certificates of qualification.

Qualifying subsidiary

600D. For the purposes of this Chapter, a subsidiary shall be a qualifying subsidiary where it is a company to which subparagraphs (ii) and (iii) of section 600F(2)(a) apply and satisfies the following conditions:

(a) the subsidiary is a 51 per cent subsidiary of

(b) no other person has control of the subsidiary;

(c) no arrangements are in existence by virtue of which the conditions specified in paragraphs (a) and (b) could cease to be satisfied.

Qualifying investment (company perspective)

600E. (1) An investment shall not be a qualifying investment unless it is based on a business plan.

(2) An investment shall not be a qualifying investment if it is an expansion risk finance investment or a follow-on risk finance investment.

(3) An investment shall not be a qualifying investment unless the qualifying company provides a copy of the certificates of qualification to the qualifying investor or qualifying partnership, as the case may be.

Certificates of qualification

600F. (1) (a) Subject to subsection (2), a company (in this section referred to as the applicant company) that is seeking to raise investments from qualifying investors or qualifying partnerships may apply to the Revenue Commissioners for the purpose of obtaining

(b) An application under paragraph (a) shall include

(2) A company shall not make an application under subsection (1) unless the following conditions are satisfied:

(a) the applicant company

(b) each company that is a member of the relief group of which the applicant company is a member

(d) the relief group of which the applicant company is a member

(3) (a) Subject to paragraphs (b) and (c), the Revenue Commissioners shall issue

(b) The Revenue Commissioners may issue to the applicant company a certificate, or renewal of a certificate, of going concern, as the case may be, having taken account of any recommendations or report which Enterprise Ireland shall make to the Revenue Commissioners following such consultation by them with Enterprise Ireland as the Revenue Commissioners consider appropriate for those purposes (including by the provision to Enterprise Ireland of such information in relation to the application as is necessary for the purposes of such consultation).

(c) The Revenue Commissioners shall issue a determination and shall not issue a certificate, or a renewal of a certificate, of going concern, as the case may be, if they have reason to believe that any condition specified in subparagraphs (i) to (v) of paragraph (a), or paragraphs (b) and (c) of subsection (2) is not, or, in the case of the renewal of a certificate, is no longer, satisfied by the relief group of which the applicant company is a member, or any company that is a member of the relief group, as the case may be.

(d) A person aggrieved by a determination issued under paragraph (a)(ii) or (c), as the case may be, may appeal the determination to the Appeal Commissioners, in accordance with section 949I, within the period of 30 days after the date of the notice of that determination.

(e) Where a company holds a valid certificate of commercial innovation but the certificate of going concern has expired or is about to expire, the company may apply to the Revenue Commissioners for a renewal of its certificate of going concern and the provisions of this section shall, with any necessary modifications, apply to an application for a renewal of a certificate of going concern as those provisions apply to an application for a certificate of going concern.

(f) Subject to section 600P, a certificate of going concern shall be valid until the later of

(4) (a) Subject to paragraphs (b) and (c), the Revenue Commissioners shall issue

(b) The Revenue Commissioners may issue to the applicant company a certificate of commercial innovation, having taken account of any recommendations or report which Enterprise Ireland shall make to the Revenue Commissioners following such consultation by them with Enterprise Ireland as the Revenue Commissioners consider appropriate for those purposes (including by the provision to Enterprise Ireland of such information in relation to the application as is necessary for the purposes of such consultation).

(c) The Revenue Commissioners shall not issue a certificate of commercial innovation if they have reason to believe that any condition specified in paragraphs (a) to (d) of subsection (2) is not satisfied by the relief group of which the applicant company is a member, or any company that is a member of that relief group, as the case may be.

(d) A person aggrieved by a determination issued under paragraph (a)(ii) may appeal the determination to the Appeal Commissioners, in accordance with section 949I, within the period of 30 days after the date of the notice of that determination.

(e) Subject to section 600P, a certificate of commercial innovation shall be valid until the date that is the seventh anniversary of the earliest of

(5) (a) Subject to paragraph (c), Enterprise Ireland may consult with any person who in the opinion of Enterprise Ireland may be of assistance to it in making any recommendations or report referred to in subsection (3)(b) or (4)(b), as the case may be, or section 600P(4)(d)(ii).

(b) Before disclosing information to any person under paragraph (a), Enterprise Ireland shall give notice in writing to the Revenue Commissioners of

(d) Before providing an approval referred to in paragraph (c), the Revenue Commissioners shall give notice in writing to the company of

and shall give the company a period of 30 days after the date of the notice to show to the satisfaction of the Revenue Commissioners that the Revenue Commissioners providing the approval referred to in paragraph (c) could prejudice the companys business.

(e) Where, on the expiry of the period referred to in paragraph (d), it is not shown to the satisfaction of the Revenue Commissioners that the provision of the approval referred to in paragraph (c) could prejudice the companys business, the Revenue Commissioners may provide that approval where the Revenue Commissioners

(f) A company aggrieved by a decision made under paragraph (e) in respect of it may appeal the decision to the Appeal Commissioners, in accordance with section 949I, within the period of 30 days after the date of the notice of that decision.

(6) Certificates of qualification shall include the following information:

(a) the type of certificate issued either in accordance with subsection (3)(a) or (4)(a), as the case may be;

(b) the name, address and company registration number, or equivalent in the case of a company incorporated outside of the State, of the qualifying company to which the certificate was issued;

(c) the date of issue of the certificate;

(d) the period of validity of the certificate;

(e) a unique, sequential certificate identification number assigned to the certificate by the Revenue Commissioners.

(7) (a) The Revenue Commissioners shall establish and maintain a register of companies to which certificates of qualification have been issued (in this subsection referred to as the register).

(b) The Revenue Commissioners shall publish the register on a website maintained by them or on their behalf.

(c) The register shall contain only the information specified in subsection (6) in respect of the certificates of qualification, and the date of withdrawal in a case where the certificates of qualification have been withdrawn under section 600P.

Subscription for shares

600G. (1) For the purposes of this Chapter, an individual subscribes for a share in a company if the individual subscribes for and is issued the share by the company

(a) for consideration consisting wholly of cash,

(b) for bona fide commercial reasons and not as part of an arrangement that it is reasonable to consider the main purpose, or one of the main purposes, of such arrangement is to secure a tax advantage to any person, and

(c) by way of a bargain at arms length,

and references in this Chapter to subscribes for shall be construed accordingly.

(2) In this Chapter, a share subscribed for, issued to, held by, or disposed of for, an individual by a nominee shall be treated for the purposes of this Chapter as subscribed for, issued to, held by, or disposed of by, the individual where the nominee has complied with the requirements of sections 892 and 894 in respect of the share.

(3) In this Chapter, references to an individual having subscribed for a share include the individual having subscribed for the share jointly with any other individual (and references to an individual holding a share or to a share being issued to an individual shall be construed accordingly).

Qualifying investor

600H. (1) For the purposes of this Chapter, a qualifying investor is an individual who on his or her own behalf subscribes for eligible shares in a qualifying company and complies with this section.

(2) (a) An individual shall not be a qualifying investor if at the date of investment the individual is connected, as determined in accordance with this section and section 600I, with the company.

(b) In this Chapter, an individual shall be connected with a company if the individual or an associate of the individual

(3) (a) Subject to subsection (4), for the purposes of this section, an individual shall have an interest in the capital of a company that is a member of the relief group if that individual, or that individuals associate, directly or indirectly possesses or is entitled to acquire

of any such company.

(b) For the purposes of paragraph (a)(ii), the loan capital of a company shall be treated as including any debt incurred by the company

but shall not include a debt incurred by the company by overdrawing an account with a person carrying on a business of banking if the debt arose in the ordinary course of that business.

(4) For the purposes of subsection (3), no account shall be taken of shares in a company which are held by the individual concerned, or an associate of that individual, where

(a) that individual or that associate, as the case may be, may be entitled to relief under section 600M on the disposal of those shares, and

(b) that individual, or a person connected with that individual, did not, at the date of investment, control the company concerned.

(5) For the purposes of this section an individual shall be treated as entitled to acquire anything which the individual is entitled to acquire at a future date or will at a future date be entitled to acquire, and there shall be attributed to any person any rights or powers of any other person who is an associate of that person.

(6) For the purposes of subsection (2), an individual shall not be connected with a company by reason that an associate of the individual

(a) has an interest in the share capital of that company, and

(b) is a partner of the individual solely by virtue of their both being partners in a qualifying investment fund within the meaning of section 508IA or a qualifying partnership.

Anti-avoidance: qualifying investor

600I. Where an individual subscribes for shares in a company with which the individual is not connected, then the individual shall nevertheless be treated as connected with it if the individual subscribes for the shares as part of any arrangement which provides for another person to subscribe for shares in another company with which the individual or any other individual who is a party to the arrangement is connected.

Qualifying investment (investor perspective)

600J. (1) Subject to sections 600K and 600L, for the purposes of this Chapter, an investment shall be a qualifying investment where

(a) an individual subscribes for eligible shares in a qualifying company, and

(b) the investment complies with this section and section 600E.

(2) An investment shall be a qualifying investment where

(a) the eligible shares held by the individual have been held for a period of at least 3 years from the date of investment,

(b) the value of the eligible shares in a qualifying company subscribed for by the individual on the date of investment

(c) throughout the period referred to in paragraph (a), the total shares, including the eligible shares, held by the individual in the qualifying company or any company that is a member of the relief group of which the qualifying company is a member

and

(d) the investor retains a copy of the certificates of qualification in respect of the qualifying company that were valid on the date of investment.

Anti-avoidance: qualifying investment (shares)

600K. (1) In this section, distribution has the same meaning as in the Corporation Tax Acts.

(2) For the purposes of this section, an amount specified or implied shall include an amount specified or implied in a foreign currency.

(3) This section applies to shares in a company where any arrangement exists which could reasonably be considered to substantially reduce the risk that the person beneficially owning those shares

(a) might, at or after a time specified in or implied by that arrangement, be unable to realise directly or indirectly in money or moneys worth an amount so specified or implied, other than a distribution, in respect of those shares, or

(b) might not receive an amount so specified or implied of distributions in respect of those shares.

(4) The reference in this section to the person beneficially owning shares shall be deemed to be a reference to both that person and any person connected with that person.

(5) An investment in shares to which this section applies shall not be a qualifying investment for the purposes of this Chapter.

(6) Without prejudice to the generality of subsection (3), such arrangements may include any rights associated with the shares as set out in the companys constitution.

Anti-avoidance: qualifying investment (investor perspective)

600L. (1) (a) For the purposes of this Chapter, an investment shall not be a qualifying investment in respect of an individual to whom this subsection applies where at any time in the period referred to in section 600J(2)(a) the company or any of its qualifying subsidiaries

(b) This subsection applies to an individual where

and the individual is that person or one of those persons.

(2) An individual shall not be entitled to relief under section 600M in respect of any shares in a company where

(a) the company comes to acquire all of the issued share capital of another company at any time in the period referred to in section 600J(2)(a), and

(b) any person or group of persons who controls or has at any such time controlled the company is a person or a group of persons who at any such time controlled that other company,

and the individual is that person or one of those persons.

(3) For the purposes of subsection (1)(b)

(a) the person or persons to whom a business belongs, and, where a business belongs to 2 or more persons, their respective shares in that business, shall be determined in accordance with paragraphs (a) and (b) of subsection (1) and subsections (2) and (3) of section 400, and

(b) any interest, rights or powers of a person who is an associate of another person shall be treated as those of that other person.

Relief

600M. (1) (a) Subject to paragraph (b), a qualifying investor who disposes of a qualifying investment in a qualifying company shall be entitled to claim relief under this section.

(b) This section shall not apply to a disposal that constitutes

(2) The amount of the chargeable gain to which this section applies is the lowest of

(a) the chargeable gain,

(b) twice the amount of the qualifying investment in the eligible shares disposed of, and

(c) an amount calculated under subsection (4)(a).

(3) Notwithstanding section 28, where an individual makes a claim under this section, the rate of capital gains tax chargeable on the amount of the chargeable gain to which this section applies shall be the rate specified in section 28 minus 17 per cent.

(4) (a) The amount calculated under this paragraph is the amount calculated by the following formula:

where G is the total amount of the chargeable gains in respect of which a claim or claims were made under this section.

(b) Where, in the return made under Part 41A in respect of a year, an individual is making a claim under this section in respect of more than one disposal of eligible shares, the amount calculated under paragraph (a) shall be calculated in respect of the earlier disposals in advance of the later disposals, and the amount calculated in respect of those earlier disposals shall be included in G in the formula in paragraph (a) in respect of those later disposals.

(5) In making a claim under this section, an individual shall, in the return required to be made under Part 41A in respect of the year in which the disposal was made, provide the following information:

(a) the name and address of the qualifying company that issued the shares;

(b) the date on which the investment was made;

(c) the value and number of shares subscribed for as part of the qualifying investment;

(d) the unique, sequential certificate identification number of the certificate of commercial innovation assigned by the Revenue Commissioners.

Qualifying partnership

600N. (1) For the purposes of this Chapter, a qualifying partnership is a partnership

(a) in which an individual is a partner and has contributed a minimum of 20,000 to the partnership prior to the date of investment by the partnership in a qualifying company, and

(b) that complies with subsection (2).

(2) A partnership shall be a qualifying partnership for the purposes of this Chapter if

(a) it is established under a partnership agreement and has as its principal business, to be expressed in the partnership agreement establishing the qualifying partnership, the investment of its funds in accordance with a defined investment policy for the benefit of its investors, and

(b) under the terms of the partnership agreement it is provided that

(3) (a) Where a qualifying partnership makes an investment of at least 20,000 in eligible shares in a qualifying company that would be, if it were made directly by an individual, a qualifying investment subject to the modifications set out in paragraph (b), then, section 600M shall apply to the disposal of those eligible shares apportionable to a partner referred to in subsection (1)(a) subject to the modifications set out in subsection (4).

(b) The modifications set out in this paragraph are that section 600J applies to an investment by a qualifying partnership as if

(4) In applying section 600M to the disposal of an investment in eligible shares which was made by an individual through a qualifying partnership, subsection (3) of that section shall apply as if references to 17 per cent were references to 15 per cent.

Interaction of relief with other provisions of this Act

600O. (1) (a) Section 597AA shall apply to a disposal, in whole or in part, of eligible shares subscribed for by, and issued to, a qualifying investor where the amount of capital gains tax payable in respect of the disposal under this Chapter is greater than the amount of capital gains tax that would be payable in respect of the disposal were section 597AA to apply.

(b) Section 600M shall not apply to a disposal referred to in paragraph (a) to which section 597AA applies.

(2) (a) Section 598 or 599, as the case may be, shall apply to a disposal, in whole or in part, of eligible shares subscribed for by, and issued to, a qualifying investor where the amount of capital gains tax payable in respect of the disposal under this Chapter is greater than the amount of capital gains tax that would be payable in respect of the disposal were section 598 or 599, as the case may be, to apply.

(b) Section 600M shall not apply to a disposal referred to in paragraph (a) to which section 598 or 599, as the case may be, applies.

(3) Section 600M shall not apply to a disposal, in whole or in part, of the eligible shares subscribed for by, and issued to, a qualifying investor where that individual has made, or intends to make, a claim for relief within the meaning of Part 16 in respect of those eligible shares.

Failure to comply with requirements of this Chapter

600P. (1) This subsection applies to a company (in this subsection referred to as the first-mentioned company) to which certificates of qualification were issued which are valid and

(a) the first-mentioned company does not satisfy the conditions specified in subsection (2)(a) of section 600F,

(b) any company that is a member of the relief group of which the first-mentioned company is a member does not satisfy the conditions specified in paragraphs (b) and (c) of subsection (2) of section 600F, or

(c) the relief group of which the first-mentioned company is a member does not satisfy the conditions specified in subsection (2)(d) of section 600F.

(2) (a) A company to which subsection (1) applies

(b) Where a company returns its certificates of qualification under paragraph (a), the Revenue Commissioners shall withdraw those certificates.

(c) Where the Revenue Commissioners withdraw the certificates of qualification under paragraph (b) they shall cease to be valid from the date of withdrawal.

(3) (a) This subsection applies to an investment and a company where the company, contrary to subsection (2)(a)(i), provided a copy of the certificates of qualification to the qualifying investor or qualifying partnership, as the case may be, who made the investment in the company.

(b) A company to which this subsection applies shall, in the year in which the certificates of qualification were provided to the qualifying investor or qualifying partnership, as the case may be, be charged to corporation tax under Case IV of Schedule D for the accounting period in which the investment to which this subsection applies was made in an amount calculated by the following formula:

where I is the investment to which this subsection applies.

(c) An amount chargeable to tax under this section shall be treated

(4) (a) Where, during the period of validity of the certificates of qualification issued to a company, there is a change in the material facts relevant to the satisfaction of the conditions specified in section 600F(2)

shall, within 30 days of the change or, in the case of an officer or agent of the company falling within subparagraph (ii) within 30 days of coming to know of the change, bring that change to the attention of the Revenue Commissioners.

(c) Where information comes to the attention of the Revenue Commissioners which causes the Revenue Commissioners to form the opinion that

then, the Revenue Commissioners shall give notice in writing to the company that they intend to withdraw the certificates of qualification.

(e) A notice under paragraph (c) shall state

(f) Where, following consideration of any submissions and such additional information or explanations as may be provided by the company pursuant to a notice under paragraph (c), and taking into account any recommendations or report which Enterprise Ireland may make to the Revenue Commissioners following such consultation by them with Enterprise Ireland as they consider appropriate for this purpose (including by the provision to Enterprise Ireland of such information in relation to the matter as is necessary for the purposes of such consultation), the opinion of the Revenue Commissioners remains that the conditions in section 600F(2)

then, the Revenue Commissioners shall issue a determination to that effect and that the certificates of qualification are withdrawn and the reasons for the determination.

(g) A person aggrieved by a determination issued under paragraph (f) may appeal the determination to the Appeal Commissioners, in accordance with section 949I, within the period of 30 days after the date of the notice of that determination.

(h) A determination under paragraph (f) shall take effect and the certificates of qualification so withdrawn shall cease to be valid

Powers

600Q. (1) The Revenue Commissioners may nominate in writing any of their officers to perform any acts and discharge any functions authorised by this Chapter to be performed or discharged by the Revenue Commissioners.

(2) An authorised officer may make such enquiries as the authorised officer considers necessary for the purpose of being satisfied as to whether

(a) information included in an application made by a company in accordance with section 600F(1) was correct and complete, and

(b) a company has complied with section 600P(2).

(3) An authorised officer may, at all reasonable times, enter any premises or place of business of a company for the purpose of carrying out the enquiries referred to in subsection (2).

(4) An authorised officer may, in respect of an applicant company (within the meaning of section 600F), require a linked business or a partner business to produce books, records or other documents and to furnish information, explanations and particulars and to give all assistance which the authorised officer may reasonably require for the purposes of his or her enquiries.

Application of the Chapter

600R. Section 600M shall apply only in respect of the disposal of eligible shares that are issued on or before 31 December 2026.

Reporting of relief by qualifying companies

600S. (1) Where, in an accounting period, a qualifying company issued shares in respect of which an entitlement to claim relief under section 600M may apply on the disposal of those shares, subsections (2) to (5) shall apply to the qualifying company for the period.

(2) A qualifying company shall include details of the qualifying investment in a return required under Part 41A for the accounting period in which the eligible shares were issued, and the company shall, notwithstanding anything to the contrary in Part 41A or section 1084, be deemed for that accounting period to be a chargeable person for the purposes of Chapter 3 of Part 41A.

(3) A qualifying company shall, not more than 4 months after the end of the year of assessment in which the shares were issued for a qualifying investment, provide to the Revenue Commissioners, through such electronic means as they make available, such information

(a) as they may require for the purposes of the annual reports required in accordance with Article 11 of the General Block Exemption Regulation, including:

and

(b) as they may require for the administration of relief under this Chapter, including:

(4) Notwithstanding any obligation to maintain secrecy or any other restriction on the disclosure of information imposed by or under statute or otherwise, the Revenue Commissioners, or any other officer authorised by them for the purposes of this subsection

(a) may furnish the information obtained in accordance with subsection (3)(a) to the person submitting the annual reports referred to in that subsection, and

(b) shall publish the following information in relation to all qualifying companies:

(5) Where a company fails to comply with a requirement to furnish information in accordance with this section, that company shall be liable to a penalty of 2,000 and, if that failure continues after the date on which the return shall be filed under Part 41A, or 30 days, as appropriate, a further penalty of 50 for each day on which the failure so continues.,

and

in section 851A(8)

by the insertion of the following subsection after subsection (4):

(4A) (a) In this subsection

deferred capital gains tax means capital gains tax arising on a relevant disposal which is deferred in accordance with paragraph (c);

relevant disposal means a disposal of qualifying assets referred to in subparagraph (v) of subsection (1)(b), in respect of which capital gains tax remains chargeable in accordance with that subparagraph;

retention period, in relation to a relevant disposal, means the period beginning on the date on which an individual makes the relevant disposal and ending on the twelfth anniversary of that date.

(b) This subsection shall apply to an individual who makes a relevant disposal to his or her child on or after 1 January 2025.

(c) An individual to whom this subsection applies may make a claim to defer payment of the capital gains tax chargeable in respect of a relevant disposal in the return required to be delivered by that individual under Chapter 3 of Part 41A for the year of assessment in which the relevant disposal is made.

(d) Where assets comprised in a relevant disposal, in respect of which a claim under paragraph (c) has been made

and

by the insertion of the following subsection after subsection (8):

(9) A claim for relief or deferral under this section shall apply only in respect of a disposal of qualifying assets where it would be reasonable to consider that the disposal of such assets is made for bona fide commercial reasons and does not form part of any arrangement or scheme the main purpose, or one of the main purposes, of which is the avoidance of liability to tax..

(a) In this subsection, Act of 2023 means the Historic and Archaeological Heritage and Miscellaneous Provisions Act 2023.

Subsection (1), in so far as it relates to the insertion of

an electronic cigarette, or

any other product consisting of

liquid containing nicotine that can be used in an e-liquid inhalation product, and

liquid not containing nicotine that can be used in an e-liquid inhalation product;

nicotine replacement means a medicine licenced or authorised by the Health Products Regulatory Authority supplied for the purpose of nicotine replacement therapy;

officer means an officer of the Commissioners;

prescribe means prescribe by regulations under section 66;

related company has the meaning assigned to it by the Companies Act 2014;

supplier means

except where paragraph (b) applies, a taxable person within the meaning of section 2 of the Value-Added Tax Consolidation Act 2010, or

an accountable person for the purposes of Part 2 of the Value-Added Tax Consolidation Act 2010,

who supplies an e-liquid product;

supply means the supply of an e-liquid product to another person, except where that person is a related company;

tax means e-liquid products tax within the meaning of section 58.

within one month after the end of an accounting period, in respect of the e-liquids products supplied in that accounting period, furnish to an officer a return in such form as the Commissioners may require showing the quantity of e-liquid product supplied by the supplier in that period and including such particulars as the Commissioners may prescribe, and

pay, in accordance with the return under paragraph (a), and by the time that that return is due, the amount of tax due in respect of the accounting period concerned.

by the insertion of the following section after section 78B:

Relief for small producers of other fermented beverages

78D. (1) In the case of

(a) cider and perry exceeding 2.8% vol, and

(b) subject to subsection (2), other fermented beverages, other than cider and perry,

that are subject to alcohol products tax, a relief of half the amount of alcohol products tax paid on such beverages shall, subject to subsection (3) and to such conditions as the Commissioners may prescribe or otherwise impose, be granted on a combined total quantity of such beverages as are referred to in paragraphs (a) and (b) not exceeding 8,000 hectolitres in a calendar year, produced by a producer of other fermented beverages

(i) where the combined total quantity of beverages referred to in paragraphs (a) and (b) and produced by that producer in the previous year has not exceeded 10,000 hectolitres,

(ii) which is legally and economically independent of any other producer of other fermented beverages,

(iii) the premises of which are situated physically apart from those of any other producer of other fermented beverages, and

(iv) where less than 50 per cent of the other fermented beverages produced by that producer in the previous calendar year have been produced under a licence, franchise or contract arrangement for another producer of other fermented beverages.

(2) (a) In the case of beverages referred to in subsection (1)(b), the relief under subsection (1) shall apply where

(b) For the purposes of paragraph (a), where the addition of alcohol to dilute or dissolve flavourings is in a dose strictly necessary such that the alcoholic strength does not increase by more than 1.2% vol, this shall not be considered as the addition of alcohol for the purpose of the production of beverages referred to in subsection (1)(b).

(c) In the case of beverages referred to in subsection (1)(b), the relief under subsection (1) shall not apply where the addition of flavourings referred to in paragraph (b) significantly alters the character of the original product.

(3) Relief under subsection (1) shall be granted by the Commissioners either by means of remission or repayment.

(4) (a) Subject to paragraph (b), relief under subsection (1) does not apply to any other fermented beverages produced for another producer of other fermented beverages under a licence, franchise or contract arrangement.

(b) Notwithstanding paragraph (a), where other fermented beverages are produced by a producer of other fermented beverages under a licence, franchise, contract or other cooperation arrangement with one or more other producers of other fermented beverages, and where

then subsection (1)(iv) does not apply, and such other fermented beverages qualify for relief under subsection (1).

(5) (a) For the purposes of subsection (1)(ii), a producer of other fermented beverages is not considered to be legally and economically independent of another producer of other fermented beverages where such producers are directly or indirectly owned or partly owned

(b) Notwithstanding subsection (1)(ii) and paragraph (a), where a person referred to in paragraph (a)(i) or (ii) directly or indirectly owns two or more producers of other fermented beverages and the combined total quantity of other fermented beverages produced by such producers in the previous calendar year has not exceeded 10,000 hectolitres, they may be treated for the purposes of this section as a single producer of other fermented beverages which is legally and economically independent of any other producer of other fermented beverages.

(6) (a) Claims for repayment under subsection (3) shall be made in such form as the Commissioners may direct and shall be in respect of payments of alcohol products tax made within a period of 3 calendar months beginning on the first day of January, April, July or October.

(b) A repayment may not be made under this section unless the claim is made within 6 months following the end of each such period or within such longer period as the Commissioners may, in any particular case, allow.,

and

by the repeal of section 78C.

by the substitution of the following definition for the definition of aid:

aid means aid granted in accordance with Commission Regulation (EU) 2023/2831;,

by the substitution of the following definition for the definition of bookmaker:

bookmaker means a person who, in the course of business

(a) takes bets,

(b) sets odds, and

(c) undertakes to pay out on winning bets;,

by the substitution of the following definition for the definition of Commission Regulation (EU) No. 1407/2013:

Commission Regulation (EU) 2023/2831 means Commission Regulation (EU) 2023/2831 of 13 December 20233131 OJ L 2023/2831, 15.12.2023 on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union to de minimis aid;,

by the substitution of the following definition for the definition of premises:

premises means any house or other building and includes a defined part of a house or other building;,

by the substitution of the following definition for the definition of proprietor:

proprietor means the person entitled to the exclusive occupation of the premises in relation to which the term is used and, where the context so admits, includes a number of persons jointly so entitled;,

by the substitution of the following definition for the definition of registered premises:

registered premises means premises for the time being registered in the register;,

by the substitution of the following definition for the definition of remote betting intermediarys licence:

remote betting intermediarys licence means a licence issued under section 7C (inserted by section 14 of the Betting (Amendment) Act 2015) of the Betting Act 1931;,

by the substitution of the following definition for the definition of remote bookmakers licence:

remote bookmakers licence means a licence issued under section 7B (inserted by section 14 of the Betting (Amendment) Act 2015) of the Betting Act 1931;,

by the substitution of the following definition for the definition of remote means:

remote means means any means by which it is possible for a person to communicate and transact with a person in another physical location, regardless of the actual physical location of those persons, and includes

(a) the internet,

(b) a telephone,

(c) money or asset transfer (whether or not electronic transfer of monies or other assets),

(d) telegraphy (whether or not wireless telegraphy);,

by the substitution of the following definition for the definition of totalisator:

totalisator means an apparatus or organisation by means of which an unlimited number of persons can each stake money in respect of a future event on the terms that the amount to be won by the successful stakers is dependent on or to be calculated with reference to the total amount staked by means of the apparatus or organisation in relation to that event but not necessarily on the same contingency, and includes all offices, tickets, recorders, and other things ancillary or incidental to the working of the apparatus or organisation;,

and

by the insertion of the following definitions:

bet means a transaction involving 2 or more persons, where

(a) the parties hold differing views regarding the outcome of an event,

(b) the parties agree that depending on the outcome of the event, one or more parties shall pay to the other or others a sum, and

(c) the event upon the outcome of which the transaction depends shall not be the outcome of a game within the meaning of this Act;

bookmakers licence means a licence issued

(a) under subsection (3) of section 7 (inserted by section 13 of the Betting (Amendment) Act 2015) of the Betting Act 1931, or

(b) in accordance with section 7A (inserted by subsection (2) of section 64 of the Irish Horseracing Industry Act 1994) of the Betting Act 1931;

game means a game (whether of skill or chance or partly of skill and partly of chance) for stakes hazarded by the players;

licensed bookmaker means a person who is the holder of a bookmakers licence or a remote bookmakers licence as the case may be;.

by the substitution of licensed bookmaker for bookmaker in each place where it occurs, and

by the substitution of the following subsection for subsection (1A):

(1A) For the avoidance of doubt, betting duty imposed by subsection (1) is chargeable on all bets placed by a person with a licensed bookmaker other than by remote means..

in section 65, by the substitution of 250 for 500,

in section 66

in section 66A

in section 66B

by the substitution of the following section for section 66C:

Payment arrangements for excise duty payable under section 65, 66A or 66B

66C. The excise duty payable under section 65, 66A or 66B, as the case may be, shall be paid in full at the time of the granting or renewal of the licence.,

by the substitution of the following section for section 66D:

Payment arrangements for excise duty payable under section 66

66D. The excise duty payable under section 66 on the registration or renewal of the registration of a premises shall be paid in full at the time of the registration or renewal of the registration.,

and

in section 78(5)(c), by the substitution of 1,000 for 2,000.

by the substitution of the following paragraph for paragraph (c):

(c) in case it is a category B vehicle

by the substitution of the following paragraph for paragraph (d):

(d) in case it is

and

by inserting the following Table after Table 2 to that subsection:

CO2 emissions (CO2 g/km)

Percentage payable of the value of the vehicle

0g/km up to and including 120g/km

8% or 160 whichever is the greater

More than 120g/km

13.3% or 266 whichever is the greater

in the definition of goods threshold, by the substitution of 85,000 for 80,000, and

in the definition of services threshold, by the substitution of 42,500 for 40,000.

in paragraph (ca), by the substitution of paragraphs 7(a), 7A, 12 and 12A for paragraphs 7(a), 7A and 12 with effect as on and from 1 January 2025, and

in paragraph (caa), by the substitution of 30 April 2025 for 31 October 2024 with effect as on and from 2 October 2024.

in paragraph (a), by the substitution of section 9(4) or 12(3), for section 9(4) or 12(3), or,

in paragraph (b), by the substitution of by him or her, or for by him or her., and

by the insertion of the following paragraph after paragraph (b):

(c) an accountable person referred to in section 22(3) or 28(4), or a taxable person who is deemed to have supplied a letting in accordance with section 28(5), in respect of supplies to which those sections apply..

the insertion of or registered with after authorised by, and

the substitution of a Member State for another Member State.

in paragraph 4, by the deletion of subparagraphs (1) and (6), and

in paragraph 6(2), by the deletion of clause (c).

in item (a) of column (1), by the substitution of fruit, vegetables, plants, grains, seeds, or pulses for fruit or vegetables, and

in column (2), by the insertion of the following item after item (d):

(e) Oat milk, almond milk, rice milk, coconut milk, hemp milk, cashew milk, soy milk, pea milk, hazelnut milk, flax milk, potato milk or other similar milk substitute drinks..

in Part 2

in Part 4, in paragraph 15(2), by the insertion of other than the supply and installation of low emissions heat pump heating systems as specified in paragraph 12A, after (including the installation of fixtures),.

in section 83DB(1), in the definition of relevant instrument, by the deletion of , where the instrument was chargeable, in respect of the whole or part of the consideration under the instrument, to stamp duty at a rate of 10 per cent, and

in Schedule 1

shall have effect as respects instruments executed on or after 2 October 2024, and

shall not have effect as respects any instrument executed before 1 January 2025, where

in section 81AA

in section 81D

by the repeal of sections 94, 102, 114 to 122 and 125B,

in section 100, by the substitution of Temple Bar Cultural Trust Designated Activity Company for Temple Bar Properties Limited in each place where it occurs, and

by the substitution of the following section for section 104:

104. (1) Stamp duty shall not be chargeable on

of the Petroleum and Other Minerals Development Act 1960, or

(b) an instrument for the sale, assignment or transfer of any licence or lease referred to in paragraph (a) or any right or interest in any such licence or lease.

(2) Subsection (1) shall apply as respects a licence or lease referred to in paragraph (a) or an instrument referred to in paragraph (b), of that subsection, where the licence, lease or instrument concerned is executed on or before 31 December 2029..

in section 31A(4), by the substitution of shall, subject to section 159A, be repaid for shall be returned, and

in section 31B(3), by the substitution of shall, subject to section 159A, be repaid for shall be returned.

in section 123B

in section 124

in subsection (1), by the substitution of the following definition for the definition of base year:

base year, in respect of each of the years 2024 and 2025, means the year 2022;,

and

by the substitution of the following subsection for subsection (2):

(2) A relevant person shall, for each of the years 2024 and 2025, not later than the due date in relation to each such year, deliver to the Commissioners a statement showing the assessable amount..

in paragraph (a), by the substitution of 400,000 for 335,000,

in paragraph (b), by the substitution of 40,000 for 32,500, and

in paragraph (c), by the substitution of 20,000 for 16,250.

in section 28

in section 46

in section 51(3), by the substitution of the following paragraphs for paragraph (a):

(a) to the extent to which section 89(4)(a) applies, for the duration of the period from the valuation date to the date the agricultural value (within the meaning of section 89) ceases to be applicable,

(aa) to the extent to which section 89A(7)(a) applies, for the duration of the period from the valuation date to the date the agricultural value (within the meaning of section 89A) ceases to be applicable,,

in section 55

in section 89, by the insertion of the following subsection after subsection (7):

(8) This section shall not apply to gifts or inheritances taken on or after the date on which section 89A comes into operation.,

in section 90(1), by the substitution of the following definition for the definition of agricultural property:

agricultural property

(a) in the case of a gift or inheritance taken prior to the date on which section 89A comes into operation, has the meaning assigned to it by section 89(1), or

(b) in the case of a gift or inheritance taken on or after the date on which section 89A comes into operation, has the meaning assigned to it by subsection (1) of that section;,

in section 102, by the substitution of section 89(2) or 89A(2), as the case may be, for section 89(2), and

in section 102A

in subsection (3)

in subsection (7)

in subsection (10)(d)

in subsection (16)(b)(ii), by the substitution of paragraphs (b) and (ba) of subsection (7) for subsection (7)(b).

by the deletion of subsection (7),

by the substitution of the following subsection for subsection (8):

(8) Where

(a) this section applies to an employer,

(b) the employer complies with the employers obligations under the Acts,

(c) the employer has

and

(d) the employer complies with the obligations of the employer under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the employer in respect of the employers Covid-19 liabilities during Period 1, Period 2 and Period 3.,

and

by the substitution of the following subsection for subsection (10):

(10) Where an employer

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the employers obligations under the Acts,

(b) is not an employer to whom subsection (8)(c) applies, or

(c) on or after 1 May 2024

simple interest shall be paid by the employer to the Revenue Commissioners on any amount of the Covid-19 liabilities remaining unpaid on

and such interest shall be calculated from

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0274 per cent..

by the deletion of subsection (10),

by the substitution of the following subsection for subsection (11):

(11) Where

(a) this section applies to a relevant person,

(b) the relevant person complies with the relevant persons obligations under the Acts,

(c) the relevant person has

and

(d) the relevant person complies with the obligations of the relevant person under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the relevant person in respect of the relevant persons Covid-19 income tax during Period 1, Period 2 and Period 3.,

and

by the substitution of the following subsection for subsection (12):

(12) Where a relevant person

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the relevant persons obligations under the Acts,

(b) is not a relevant person to whom subsection (11)(c) applies, or

(c) on or after 1 May 2024

simple interest shall be paid by the relevant person to the Revenue Commissioners on any amount of the Covid-19 income tax remaining unpaid on

and such interest shall be calculated from

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0219 per cent..

by the deletion of subsection (6),

by the substitution of the following subsection for subsection (7):

(7) Where

(a) this section applies to an employer,

(b) the employer complies with the employers obligations under the Acts,

(c) the employer has

and

(d) the employer complies with the obligations of the employer under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the employer in relation to the employers liability in respect of Covid-19 relevant tax during Period 1, Period 2 and Period 3.,

and

by the substitution of the following subsection for subsection (8):

(8) Where an employer

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the employers obligations under the Acts,

(b) is not an employer to whom subsection (7)(c) applies, or

(c) on or after 1 May 2024

simple interest shall be paid by the employer to the Revenue Commissioners in relation to any amount of the Covid-19 relevant tax remaining unpaid on

and such interest shall be calculated from

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0219 per cent..

by the deletion of subsection (6),

by the substitution of the following subsection for subsection (7):

(7) Where

(a) this section applies to an employer,

(b) the employer complies with the employers obligations under the Acts,

(c) the employer has

and

(d) the employer complies with the obligations of the employer under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the employer in relation to the employers liability in respect of Covid-19 relevant tax during Period 1, Period 2 and Period 3.,

and

by the substitution of the following subsection for subsection (8):

(8) Where an employer

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the employers obligations under the Acts,

(b) is not an employer to whom subsection (7)(c) applies, or

(c) on or after 1 May 2024

simple interest shall be paid by the employer to the Revenue Commissioners in relation to any amount of the Covid-19 relevant tax remaining unpaid on

and such interest shall be calculated from

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0219 per cent..

by the deletion of subsection (7),

by the substitution of the following subsection for subsection (8):

(8) Where

(a) this section applies to an accountable person,

(b) the accountable person complies with the accountable persons obligations under the Acts,

(c) the accountable person has

and

(d) the accountable person complies with the obligations of the accountable person under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the accountable person in respect of the accountable persons Covid-19 liabilities during Period 1, Period 2 and Period 3.,

and

by the substitution of the following subsection for subsection (10):

(10) Where an accountable person

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the accountable persons obligations under the Acts,

(b) is not an accountable person to whom subsection (8)(c) applies, or

(c) on or after 1 May 2024

simple interest shall be paid by the accountable person to the Revenue Commissioners on any amount of the Covid-19 liabilities remaining unpaid on

and such interest shall be calculated from

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0274 per cent..

by the deletion of subsection (7),

by the substitution of the following subsection for subsection (8):

(8) Where

(a) this section applies to an employer,

(b) the employer complies with the employers obligations under section 17A,

(c) the employer has

and

(d) the employer complies with the obligations of the employer under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the employer in respect of the employers Covid-19 liabilities during Period 1, Period 2 and Period 3.,

and

by the substitution of the following subsection for subsection (10):

(10) Where an employer

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the employers obligations under section 17A,

(b) is not an employer to whom subsection (8)(c) applies, or

(c) on or after 1 May 2024

simple interest shall be paid by the employer to the Revenue Commissioners on any amount of the Covid-19 liabilities remaining unpaid on

and such interest shall be calculated from

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0274 per cent..

in Part 1, by the insertion of the following paragraph after paragraph 30:

30A. The Double Taxation Relief (Taxes on Income) (Sultanate of Oman) Order 2024 (S.I. No. 485 of 2024).,

and

in Part 3, by the substitution of the following paragraph for paragraph 7:

7. The Exchange of Information Relating to Tax Matters and Double Taxation Relief (Taxes on Income) (Jersey) Order 2010 (S.I. No. 28 of 2010) and the Double Taxation Relief (Taxes on Income) (Jersey) Order 2024 (S.I. No. 484 of 2024)..

in section 653A(2), by the substitution of other than in the definition of planning permission period in subsection (1) and in the definition of relevant appeal in section 653AF(1) for other than in subsection (1) and section 653AF(1)(a),

in section 653I

by the insertion of the following section after section 653I:

Exemption on submission of request for change to zoning of land included on revised map for the year 2025

653IA. (1) This subsection applies to a relevant site where

(a) a person has made a submission under subsection (1)(d) of section 653I in respect of lands which are, or include, such relevant site,

(b) the submission referred to in paragraph (a) is acknowledged by the local authority in accordance with subsection (3A) of section 653I, and

(c) as at the date on which the acknowledgement referred to in paragraph (b) is issued

(2) Where subsection (1) applies to a relevant site, notwithstanding section 653Q, on the making of a claim by a liable person under this Part in relation to the relevant site, residential zoned land tax shall not be charged and levied in respect of that site on 1 February 2025.

(3) This subsection applies to a relevant site where

(a) a person has made a submission under subsection (1)(d) of section 653I in respect of lands which are, or include, such relevant site,

(b) the submission referred to in paragraph (a) is acknowledged by the local authority in accordance with subsection (3A) of section 653I, and

(c) the relevant site is the subject of one or more current planning applications for residential development and the current planning application for residential development or, where there is more than one such applications, all of them taken together, are in respect of part, but not all, of a relevant site.

(4) Such part of a relevant site referred to in subsection (3) as is not the subject of one or more current planning applications for residential development referred to in that subsection shall, for the purposes of subsection (5), be regarded as the eligible part of the relevant site.

(5) Where subsection (3) applies to a relevant site, notwithstanding section 653Q, on the making of a claim by a liable person under this Part in relation to the relevant site, residential zoned land tax shall not be charged and levied in respect of the eligible part of the relevant site on 1 February 2025.

(6) A claim referred to in subsection (2) or (5) shall be made in such form and contain such particulars as the Revenue Commissioners may prescribe.,

in section 653O, by the insertion of the following subsection after subsection (3):

(3A) Where

(a) a site would, but for this subsection, become a relevant site on a particular date,

(b) a planning permission was granted in respect of a portion of the site prior to that date, and

(c) the planning permission period has not expired on that date,

that portion of the site referred to in paragraph (b) and the remainder of the site of which it forms a portion shall, from that date each be a separate relevant site for the purposes of this Part.,

in section 653T(2)(e), by the substitution of including of any claims made in accordance with section 653IA, 653AD, 653AE, 653AF, 653AFA, 653AFB, 653AGA, 653AH, 653AHA or 653AI for including of any claims made in accordance with section 653AD, 653AE, 653AF, 653AFA, 653AFB, 653AH, 653AHA or 653AI,

in section 653AD, by the insertion of the following subsections after subsection (6):

(6A) This subsection applies where

(a) this section and section 653AGA apply in respect of a site, and

(b) the date specified in the notification under subsection (2) is before the date of the grant of planning permission or, where section 653AGA(2) applies, the date on which the relevant appeal or relevant petition, as the case may be, in respect of the planning permission is determined.

(6B) Where subsection (6A) applies, on the making of a claim by the liable person, residential zoned land tax deferred in accordance with section 653AGA in respect of a site shall not be due and payable in respect of the site, or part of the site, affected in the manner described in subsection (1).

(6C) Where only part of the site is affected in the manner described in subsection (1), the amount of residential zoned land tax deferred in accordance with section 653AGA that is not due and payable in accordance with subsection (6B), shall be determined by the formula in subsection (6), subject to the following modifications:

C shall be the amount of deferred tax which is not due and payable,

T shall be the total amount of deferred residential zoned land tax in respect of the site,

Apart shall be the area, in square metres, of the part of the site affected in the manner described in subsection (1), and

Atotal shall be the total area, in square metres, of the site.,

in section 653AF

by the insertion of the following section after section 653AG:

Deferral of residential zoned land tax in respect of grant of planning permission

653AGA. (1) This section applies where

(a) a planning permission has been granted in respect of a relevant site,

(b) that planning permission, subject to subsection (2), is not the subject of a relevant appeal or relevant petition, and

(c) no commencement notice in respect of the development of the relevant site has been lodged with the local authority in whose functional area the relevant site is situated.

(2) Where a relevant appeal or relevant petition is made in respect of a grant of planning permission and the relevant appeal or relevant petition is determined such that the grant of planning permission is upheld, a reference in this section to the date of grant of planning permission shall be read as a reference to the date on which that relevant appeal or relevant petition, as the case may be, is determined.

(3) Subject to subsections (4), (5) and (6), where this section applies, so much of any residential zoned land tax arising in respect of a liability date, in relation to a relevant site, after the date of grant of planning permission in respect of the relevant site shall, notwithstanding section 653Q(2), not be due and payable until the earlier to occur of

(a) the expiration of the period of 12 months from the date of grant of planning permission, and

(b) the date on which there is a change in the ownership of the relevant site, or part thereof,

and residential zoned land tax so deferred shall be referred to in this section as pre-development deferred residential zoned land tax.

(4) (a) In this subsection

group has the same meaning as it has in section 616;

member of a group has the same meaning as it has in section 616.

(b) This subsection applies where

(c) Where this subsection applies, for the purpose of this section

(d) Where pre-development deferred residential zoned land tax becomes due and payable in accordance with subsection (3) or (6) in relation to the relevant site, or the part of the relevant site, as the case may be, which was transferred, the transferor company and transferee company shall be jointly and severally liable for such tax.

(5) (a) This subsection applies where a commencement notice in respect of development of a relevant site in respect of which this section applies has been lodged with the local authority in whose functional area the relevant site is situated, before the expiration of the period referred to in subsection (3)(a), such that

as appropriate.

(b) Where this subsection applies, for each liability date falling within the period from the date of grant of planning permission to the date the commencement notice concerned is lodged

(c) Where the development consists of residential development only, the relevant amount is the amount of pre-development deferred residential zoned land tax.

(d) Where the development consists of residential development and development other than residential development, the relevant amount is the amount represented by W in the formula:

where

(e) Where the development consists of development other than residential development, in whole or in part, the relevant amount is the amount represented by Y in the formula

where

(6) (a) Where

(referred to in this subsection as a part ownership change) the amount of any pre-development deferred residential zoned land tax in respect of that part of the relevant site so transferred which

shall be the amount represented by A in the formula

where

(b) Following a part ownership change, subsection (3) shall continue to apply as if the part ownership change did not occur.

(7) Where pre-development deferred residential zoned land tax becomes due and payable in accordance with subsection (3) or (6), the liable person shall amend each return in respect of each liability date concerned and pay any tax and interest due accordingly.

(8) This section only applies if a return referred to in section 653T is delivered to the Revenue Commissioners in respect of each liability date to which this section refers, notwithstanding subsection (3).

(9) Where this section has been applied in respect of a planning permission pertaining to land representing a relevant site, it shall not apply in respect of any other planning permission pertaining to that land or any portion of that land.,

in section 653AH

in section 653AI

in section 111A

in section 111B(1), in the definition of OECD Pillar Two guidance, by the substitution of the following paragraph for paragraph (b):

(b) the document entitled OECD (2024), Tax Challenges Arising from the Digitalisation of the Economy Global Anti-Base Erosion Model Rules (Pillar Two) Examples, OECD, Paris, published by the OECD on 25 April 2024,,

in section 111C(1), by the substitution of Subject to subsection (2) and sections 111AL, 111AAA and 111AAD for Subject to subsection (2) and section 111AL,

in section 111S(1), by the substitution of the MNE group or large-scale domestic group for an MNE group or large-scale domestic group,

in section 111V(3)(a)(ii), by the insertion of for a price equal to, or exceeding, the marketable price floor after origination year,

in section 111X

in section 111Z

in section 111AA(1), in the definition of jurisdictional ETR, by the insertion of entities located in after the effective tax rate for,

in section 111AI

in section 111AJ

in Chapter 5, by the insertion of the following section after section 111AK:

Simplified calculations safe harbour

111AKA. (1) In this section

CbC report has the same meaning as in section 111AJ(1);

non-material constituent entity means a constituent entity, including its permanent establishments, that is a member of an MNE group or large-scale domestic group, as the case may be, and that is not consolidated on a line-by-line basis in the ultimate parent entitys consolidated financial statements solely on size or materiality grounds, provided that

(a) the consolidated financial statements are consolidated financial statements to which paragraph (a) or (c), as the case may be, of the definition of that term in section 111A(1) applies,

(b) the consolidated financial statements are audited by an external independent auditor and that auditors opinion on the consolidated financial statements does not contain any objections or qualifications in relation to the entity not being consolidated on a line-by-line basis, and

(c) in the case of an entity with a total revenue, as determined in accordance with the relevant CbC regulations in respect of the fiscal year, that exceeds 50,000,000, its financial accounts, that are used to complete the CbC report for the group of which the entity is a member, are prepared in accordance with an acceptable financial accounting standard or an authorised financial accounting standard;

NMCE means non-material constituent entity;

NMCE simplified calculations means the simplified income calculation, the simplified revenue calculation and the simplified tax calculation;

OECD Report of 2015 and OECD CBCR Guidance have the meaning assigned to them, respectively, in section 111AJ(1);

relevant CbC regulations means the Country-by-Country Reporting regulations of the jurisdiction in which the ultimate parent entity of an MNE group is located, or where the surrogate parent entity is located if a CbC report is not filed by the MNE group in the jurisdiction of the ultimate parent entity, but where an MNE group is not required to file a CbC report in any jurisdiction, it shall mean the OECD Report of 2015 and the OECD CBCR Guidance;

simplified income calculation means the qualifying income or loss of an NMCE is equal to the total revenue as determined in accordance with the relevant CbC regulations in respect of the fiscal year;

simplified revenue calculation means the qualifying revenue of an NMCE is equal to the total revenue as determined in accordance with the relevant CbC regulations in respect of the fiscal year;

simplified tax calculation means the adjusted covered taxes of an NMCE is equal to its current year income tax accrued as determined in accordance with the relevant CbC regulations in respect of the fiscal year;

surrogate parent entity means a constituent entity appointed by an MNE group as a sole substitute for the ultimate parent entity, to file a CbC report on behalf of the MNE group.

(2) Subject to subsection (3), notwithstanding section 111AD(3), at the election of the filing constituent entity, the jurisdictional top-up tax for a jurisdiction for a fiscal year, other than additional top-up tax for a jurisdiction for a fiscal year determined in accordance with section 111AF, shall be deemed to be zero where the MNE group or large scale domestic group, as the case may be, meet the requirements set out in subsection (4), (5) or (6).

(3) An election shall not be made in respect of a jurisdiction under subsection (2) where there is no NMCE of the MNE group or large-scale domestic group, as the case may be, located in the jurisdiction for the fiscal year.

(4) The requirements of this subsection shall be met where there is no excess profit determined for a jurisdiction for a fiscal year in accordance with section 111AD(4).

(5) The requirements of this subsection shall be met where

(a) the average qualifying revenue of all constituent entities of an MNE group or large-scale domestic group, as the case may be, located in a jurisdiction is less than 10,000,000, and

(b) the average qualifying income or loss of all constituent entities of an MNE group or large-scale domestic group, as the case may be, in that jurisdiction is a loss or is less than 1,000,000,

where the average qualifying revenue and average qualifying income or loss of all constituent entities of an MNE group or large-scale domestic group are determined in accordance with section 111AG.

(6) The requirements of this subsection shall be met where the effective tax rate of a jurisdiction for a fiscal year calculated in accordance with section 111AC is equal to or greater than the minimum tax rate.

(7) Notwithstanding sections 111O(1), 111U and 111AG(3), for the purposes of this section, a filing constituent entity may make an election to determine the qualifying income or loss, qualifying revenue and adjusted covered taxes of an NMCE for a fiscal year using the NMCE simplified calculations.

(8) (a) Where a main entity is not an NMCE then none of its permanent establishments shall be considered to be an NMCE but where a main entity is an NMCE then all of its permanent establishments shall be considered to be NMCEs.

(b) In the case of a permanent establishment that is an NMCE, the amount of the NMCE simplified calculations shall be determined under the relevant CbC regulations with respect to such permanent establishment.

(9) All relevant information concerning the application of the simplified calculations safe harbour shall be included in the top-up tax information return for the fiscal year in accordance with section 111AAI.

(10) The elections referred to in subsections (2) and (7) shall be made in accordance with section 111AAAD.,

in section 111AS(7)(a)(ii), by the substitution of transfers substantially all of its assets to a person for substantially all of its assets are transferred to a person,

in section 111AT(4)(b), by the substitution of top-up tax for effective tax rate,

in section 111AW

in section 111AY(1)(b)

in section 111AAA, by the designation of that section as subsection (1) and by the insertion of the following subsection after subsection (1):

(2) Chapter 10 shall apply for the purpose of administering the charge to domestic top-up tax of a qualifying entity.,

in section 111AAB(1)(c)

in section 111AAC, by the insertion of the following subsection after subsection (3):

(4) (a) Subject to paragraph (b), where a securitisation entity is a member of an MNE group or large-scale domestic group, then no domestic top-up tax shall be charged on that securitisation entity for a fiscal year and for the purposes of determining the domestic top-up tax of all the other qualifying entities, excluding securitisation entities, of that MNE group or large-scale domestic group for the fiscal year, section 111AD(5) shall apply as if the sum, if any, of the qualifying income of all the qualifying entities of that MNE group or large-scale domestic group for a fiscal year located in the State excluded the qualifying income, if any, of the securitisation entity.

(b) Paragraph (a) shall not apply where there are no entities of an MNE group or large-scale domestic group located in the State in a fiscal year other than a securitisation entity.,

in section 111AAD

in section 111AAF

in section 111AAH, by the substitution of the following subsection for subsection (1):

(1) (a) An entity that is subject to IIR top-up tax for a fiscal year (in this Chapter referred to as a relevant parent entity), shall give notice to the Revenue Commissioners, in the form and manner specified by the Revenue Commissioners, that it is such an entity, not later than

(b) An entity that is subject to UTPR top-up tax for a fiscal year (in this Chapter referred to as a relevant UTPR entity) shall give notice to the Revenue Commissioners in the form and manner specified by the Revenue Commissioners, that it is such an entity, not later than

(c) A qualifying entity shall give notice to the Revenue Commissioners, in the form and manner specified by the Revenue Commissioners, that it is such an entity, not later than

in section 111AAZ(5), by the substitution of entity for constituent entity, and

in section 111AAAD

subparagraphs (i)(II) and (iii) of paragraph (a);

subparagraph (ii) of paragraph (g);

paragraphs (k), (p), (q), (r), (t) and (u);

subparagraphs (ii), (iii), (iv) and (v) of paragraph (w).

are amended to the extent and in the manner specified in paragraphs 1 to 3 of that Schedule, and

apply and come into operation in accordance with paragraph 4 of that Schedule.

in so far as it relates to income tax, the Income Tax Acts,

in so far as it relates to universal social charge, Part 18D of the Principal Act,

in so far as it relates to corporation tax, the Corporation Tax Acts, and

in so far as it relates to capital gains tax, the Capital Gains Tax Acts.

income tax, shall be construed together with the Income Tax Acts,

residential zoned land tax, shall be construed together with Part 22A of the Principal Act,

vacant homes tax, shall be construed together with Part 22B of the Principal Act,

corporation tax, shall be construed together with the Corporation Tax Acts,

capital gains tax, shall be construed together with the Capital Gains Tax Acts,

duties of excise, shall be construed together with the statutes which relate to duties of excise and the management of those duties,

value-added tax, shall be construed together with the Value-Added Tax Acts,

stamp duty, shall be construed together with the Stamp Duties Consolidation Act 1999 and the enactments amending or extending that Act,

gift tax or inheritance tax, shall be construed together with the Capital Acquisitions Tax Consolidation Act 2003 and the enactments amending or extending that Act, and

the temporary wage subsidy or the wage subsidy payment provided for by Part 7 of the next-mentioned Act, shall be construed together with Part 7 of the Emergency Measures in the Public Interest (Covid-19) Act 2020 and the enactments amending or extending that Act.

The Taxes Consolidation Act 1997 is amended

in section 860(1), by the substitution of A Peace Commissioner for Subject to subsection (2), a Peace Commissioner,

in section 959C(1), by the substitution of other than a self assessment for other that a self assessment,

in section 959V(2A), by the substitution of whether paragraph (a), (b) or (c) applies for which of paragraphs (a), (b) and (c) applies, and

in section 959AT(2)(b)(iii), by the substitution of by the claimant company for the accounting period, for by the claimant company for the accounting period, or.

The Finance Act 1992 is amended

in section 130

in section 132(3)(a)(i)(II)(B), by the substitution of 820 for 740.

Schedule 1 to the Stamp Duties Consolidation Act 1999 is amended in the heading CONVEYANCE or TRANSFER on sale of any property other than stocks or marketable securities or a policy of insurance or a policy of life insurance, by the substitution of the following paragraph for paragraph (5)

the instrument is executed on or after 1 January 2015 and before 1 January 2029,

the individual to whom the property is being conveyed or transferred is an individual

in a case where subparagraph (b)(i)(II) applies, the individual to whom the land is leased

the land is farmed on a commercial basis and with a view to the realisation of profits from that land, and

the person becoming entitled to the entire beneficial interest in the property (or, where more than one person becomes entitled to a beneficial interest in the property, each of them) is related to the person or each of the persons immediately theretofore entitled to the entire beneficial interest in the property in one or other of the following ways, that is, as a lineal descendant, parent, grandparent, step parent, husband or wife, brother or sister of a parent or brother or sister, or lineal descendant of a parent, husband or wife or brother or sister, or is, as respects the person or each of the persons immediately theretofore entitled, his or her civil partner, the civil partner of either of his or her parents or a lineal descendant of his or her civil partner.

1 per cent of the consideration which is attributable to property which is not residential property but where the calculation results in an amount which is not a multiple of 1 the amount so calculated shall be rounded down to the nearest .

Subparagraph (b) of paragraph 2 is deemed to have come into operation on and from 1 January 2022.