Finance (No. 2) Act 2023

Type Act

Publication 2023-12-18

State In force

Source Irish Statute Book

articles 102

(II) where the certificate was renewed in accordance with paragraph (e), the day on which the certificate of commercial innovation referred to in that paragraph ceases to be valid.

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

(i) a certificate (in this Chapter referred to as a ‘certificate of commercial innovation’) to a qualifying company where the company demonstrates to the satisfaction of the Revenue Commissioners that it satisfies the conditions specified in subparagraphs (vi) and (vii) of subsection (2)(a), or

(ii) a determination that the applicant company has not demonstrated to the satisfaction of the Revenue Commissioners that it satisfies the conditions specified in subparagraphs (vi) and (vii) of subsection (2)(a) and the reasons for the determination.

(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 may make to the Revenue Commissioners following such consultation by them with Enterprise Ireland as they 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) (i) 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.

(ii) Where a certificate of commercial innovation is not issued because a condition specified in subparagraph (i) or (ii), as the case may be, of subsection (2)(d), is not satisfied, then the Revenue Commissioners shall issue a determination that the applicant company has not demonstrated to the satisfaction of the Revenue Commissioners that the relief group of which the applicant company is a member satisfies the condition concerned and the reasons for the determination.

(d) A person aggrieved by a determination issued under paragraph (a)(ii) or (c)(ii), 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) Subject to section 600P, a certificate of commercial innovation shall be valid until the first date that is the fifth anniversary of the registration of any company that is a member of the relief group of which the applicant company is a member, or, if earlier, where any company that is a member of that relief group was formed by way of merger, the date that is the first date that is the fifth anniversary of the registration of any company that was party to the merger.

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

(a) the type of certificate;

(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;

(d) the period of validity of the certificate;

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

(6) (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 (5) in respect of each certificate of qualification, and the date of withdrawal in a case where 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

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—

(i) is a partner of the company, or of any company that is a member of the relief group of which that company is a member,

(ii) is a director or employee of the company, or of any company that is a member of the relief group of which that company is a member, or

(iii) subject to subsection (3), has an interest in the capital of the company, or of any company that is a member of the relief group of which that company is a member.

(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 individual’s associate, directly or indirectly possesses or is entitled to acquire—

(i) any of the issued share capital,

(ii) any of the loan capital,

(iii) any of the voting power, or

(iv) rights to the assets on a winding up, 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—

(i) for any money borrowed or capital assets acquired by the company,

(ii) for any right to receive income created in favour of the company, or

(iii) for consideration the value of which to the company was, at the time when the debt was incurred, substantially less than the amount of the debt (including any premium on the debt),

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.

(c) (i) For the purposes of paragraph (a)(iv), an individual shall have a right to the assets on a winding up if that individual, or an associate of the individual, has rights as would, in the event of the winding up of a company or in other circumstances, entitle the individual to receive any assets of the company which would at that time be available for distribution to equity holders of the company, and for the purposes of this subsection—

(I) the persons who are equity holders of the company, and

(II) the percentage of the assets of the company to which the individual would be entitled,

shall be determined in accordance with sections 413 and 415, with references in section 415 to the first company being construed as references to an equity holder and references to a winding up being construed as including references to any other circumstances in which assets of the company are available for distribution to its equity holders.

(ii) In applying sections 413 and 415 in determining the percentage of share capital or other amount which a shareholder beneficially owns or is beneficially entitled to under subparagraph (i), no regard shall be had to the provisions of section 411(1)(c).

(d) (i) For the purposes of this section, an individual shall have an interest in the capital of the company if the individual has control of it.

(ii) For the purposes of this section, an individual shall be treated as having an interest in the capital of the company if the individual has, at the date of investment, control of another company which is a subsidiary of the company.

(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—

(i) is not less than €20,000, or

(ii) is not less than €10,000, and at the time of the investment—

(I) the eligible shares held by the individual represent not less than 5 per cent of the qualifying company’s ordinary share capital, and

(II) the eligible shares held by the individual entitle the individual to not less than 5 per cent of—

(A) the profits available for distribution to equity holders of the qualifying company,

(B) the voting rights of the qualifying company, and

and

(III) there exist no arrangements which could reasonably be considered to—

(A) cause the individual’s holding of eligible shares to fall below 5 per cent, or

(B) reduce the individual’s entitlements, referred to in clause (II) in respect of the eligible shares, below 5 per cent,

(c) throughout the period referred to 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—

(i) represent not more than 49 per cent of the company’s ordinary share capital, and

(ii) do not entitle the individual to more than 49 per cent of—

(I) the profits available for distribution to equity holders of the company,

(II) the voting rights of the company, and

(III) the assets of the company available for distribution to equity holders,

and

(d) the investor retains a copy of 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 money’s 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 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 company’s 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—

(i) begins to carry on a business previously carried on at any time in that period otherwise than by the company or any of its qualifying subsidiaries, or

(ii) acquires the whole or greater part of the assets used for the purposes of a business previously so carried on.

(b) This subsection applies to an individual where—

(i) any person or group of persons to whom an interest amounting in the aggregate to more than a 50 per cent share in the business (as previously carried on) belonged at any time in the period referred to in section 600J(2)(a) is a person or a group of persons to whom such an interest in the business carried on by the company, or any of its subsidiaries, belongs or has at any such time belonged, or

(ii) any person or group of persons who controls or at any such time has controlled the company is a person or a group of persons who at any such time controlled another company which previously carried on the business,

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—

(i) the redemption, repayment or repurchase of shares by a company, or

(ii) a disposal within the meaning of section 534(b).

(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

(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:

€3,000,000 G

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;

(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—

(i) the funds to be invested in eligible shares are to be invested without undue delay,

(ii) pending investment in eligible shares, any moneys subscribed for the purchase of shares are to be placed on deposit in a separate account with a bank licensed to transact business in the State,

(iii) any amounts received by means of dividends or interest are, subject to a commission in respect of management expenses at a rate not exceeding a rate which shall be specified in the partnership agreement, to be paid without undue delay to the partners,

(iv) any charges to be made by means of management or other expenses in connection with the establishment, running, winding down or termination of the partnership shall be at a rate not exceeding a rate which shall be specified in the partnership agreement, and

(v) audited accounts of the partnership are prepared annually and submitted to the Revenue Commissioners when requested.

(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—

(i) subparagraph (ii) of subsection (2)(b) of that section were deleted, and

(ii) references to ‘the individual’ in paragraph (c) of subsection (2) of that section were references to ‘the qualifying partnership’.

(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—

(i) shall not provide copies of its certificates of qualification to a qualifying investor or a qualifying partnership, as the case may be, and

(ii) shall return its certificates of qualification to the Revenue Commissioners.

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

(I X 2 X 17 per cent) X 4

where I is the investment to which this subsection applies.

(i) as income against which no loss, deficit, expense or allowance may be set off, and

(ii) as not forming part of the income of the company for the purposes of calculating a surcharge under section 440.

(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)—

(i) the company, or

(ii) any officer or agent of the company who has knowledge of the change,

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.

(b) (i) An individual who does not comply with paragraph (a) shall be liable to a penalty of €3,000.

(ii) Where a company does not comply with paragraph (a)—

(I) the company shall be liable to a penalty of €4,000, and

(II) the secretary of the company shall be liable to a separate penalty of €3,000.

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

(i) there has been a change in a material fact relevant to the satisfaction of any of the conditions specified in section 600F(2), or

(ii) any of the conditions specified in section 600F(2) were not satisfied at the date of application under section 600F(1) or the date on which the certificates of qualification were issued or renewed, as the case may be,

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

(d) For the purposes of paragraph (c), the Revenue Commissioners shall take 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).

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

(i) the reasons for the intention to withdraw the certificates of qualification, and

(ii) that the company has a period of 30 days to make submissions and to provide such information and explanations as are necessary to prove to the satisfaction of the Revenue Commissioners that the conditions specified in section 600F(2)—

(I) continue to be satisfied, in a case where paragraph (c)(i) applies, or

(II) were satisfied, in a case where paragraph (c)(ii) applies.

(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)—

(i) are not satisfied, in a case where paragraph (c)(i) applies, or

(ii) were not satisfied, in a case where paragraph (c)(ii) applies,

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—

(i) where no appeal against the determination is brought under paragraph (g), on the expiration of the period specified in paragraph (g) for bringing an appeal, or

(ii) where an appeal if brought under paragraph (g), on the date on which the determination is confirmed on appeal or the appeal is withdrawn, abandoned or otherwise not proceeded with, as the case may be.

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, 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 this Chapter

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

and

(b) in section 851A—

(i) in subsection (8)—

(I) in paragraph (n), by the deletion of “and” after “functioning of the European Union,”,

(II) in paragraph (o), by the substitution of “European Union, and” for “European Union.”, and

(III) by the insertion of the following paragraph after paragraph (o):

“(p) where the taxpayer information is disclosed to Enterprise Ireland for the sole purpose of the consultation referred to in subsection (3)(b) or (4)(b), as the case may be, of section 600F.”,

and

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

“(8C) In relation to the disclosure of information referred to in paragraph (p) of subsection (8), Enterprise Ireland shall notify the Revenue Commissioners in writing of its intention to engage a person for either or both of the purposes referred to in that paragraph and shall not engage the person if, within the period of 30 days from the date of the notification, the Revenue Commissioners have objected to the engagement of that person.”.

(2) Subsection (1) shall come into operation on such day as the Minister for Finance may appoint by order.

47. Amendment of section 536 of Principal Act (capital sums: receipt of compensation and insurance moneys not treated as a disposal in certain cases)

47. (1) Section 536 of the Principal Act is amended by the insertion of the following subsection after subsection (4):

“(5) This section shall not apply to a disposal or deemed disposal of, or of an interest in, property situate in the State to an authority possessing compulsory purchase powers, where the disposal or deemed disposal, as the case may be, would not have been made but for—

(a) the exercise of those powers, or

(b) the giving by the authority of formal notice of its intention to exercise those powers.”.

(2) Subsection (1) applies to disposals and deemed disposals referred to in that subsection made on or after the date of the passing of this Act.

48. Amendment of section 597AA of Principal Act (revised entrepreneur relief)

48. Section 597AA of the Principal Act is amended, in subsection (1)(a), by the substitution of the following definition for the definition of “holding company”:

“ ‘holding company’ means a company—

(i) that holds shares in other companies, all of which are its 51 per cent subsidiaries, and

(ii) whose business consists wholly or mainly of the holding of shares in the subsidiaries referred to in subparagraph (i);”.

49. Amendment of section 598 of Principal Act (disposals of business or farm on “retirement”)

49. Section 598 of the Principal Act is amended—

(a) in subsection (1)(a)—

(i) in the definition of “payment entitlement”, by the substitution of “Regulation (EU) 2021/2115 of the European Parliament and of the Council of 2 December 2021[^14]” for “Regulation (EU) No. 1307/2013 of the European Parliament and of the Council of 17 December 2013”, and

(ii) by the insertion of the following definition:

“ ‘relevant year of assessment’ means the year of assessment in which the disposal for which relief is claimed under this section or section 599 is made;”,

(b) in subsection (2)—

(i) in paragraph (a), by the insertion of “on or before 31 December 2024” after “qualifying assets”,

(ii) in paragraph (c), by the insertion of “and on or before 31 December 2024” after “2014”,

(iii) by the insertion of the following paragraphs after paragraph (c):

“(ca) Subject to this section, where an individual who has attained the age of 55 years but has not attained the age of 70 years disposes of the whole or part of his or her qualifying assets on or after 1 January 2025, then—

(i) if the amount or value of the consideration for the disposal does not exceed €750,000, relief shall be given in respect of the full amount of capital gains tax chargeable on any gain accruing on the disposal, and

(ii) if the amount or value of the consideration for the disposal exceeds €750,000, the amount of capital gains tax chargeable on the gain accruing on the disposal shall not exceed 50 per cent of the difference between the amount of that consideration and €750,000.

(cb) Subject to this section, where an individual who has attained the age of 70 years disposes of the whole or part of his or her qualifying assets on or after 1 January 2025, then—

(i) if the amount or value of the consideration for the disposal does not exceed €500,000, relief shall be given in respect of the full amount of capital gains tax chargeable on any gain accruing on the disposal, and

(ii) if the amount or value of the consideration for the disposal exceeds €500,000, the amount of capital gains tax chargeable on the gain accruing on the disposal shall not exceed 50 per cent of the difference between the amount of that consideration and €500,000.”,

and

(iv) in paragraph (d), by the substitution of “paragraphs (a) to (cb)” for “paragraphs (a), (b) and (c)”,

(a) and (ca) of subsection (2) were a reference to” for “the age referred to in subsection (2) were”,

(d) in subsection (3B)(b)(ii)(II), by the substitution of “in paragraphs (a) and (ca) of subsection (2)” for “in subsection (2)(a)”, and

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

“(9) A claim for relief under this section shall be made by the individual making the claim in the return required to be delivered by that individual under Chapter 3 of Part 41A for the relevant year of assessment.”.

50. Amendment of section 599 of Principal Act (disposals within family of business or farm)

50. Section 599 of the Principal Act is amended—

(a) in subsection (1)—

(i) in paragraph (b)—

(I) in subparagraph (i), by the insertion of “on or before 31 December 2024” after “his or her child”,

(II) in subparagraph (iia), by the insertion of “and on or before 31 December 2024” after “2014”,

(III) in subparagraph (iii), by the insertion of “and on or before 31 December 2024” after “2014”, and

(IV) by the insertion of the following subparagraphs after subparagraph (iii):

“(iv) where an individual who has attained the age of 55 years but has not attained the age of 70 years disposes of the whole or part of his or her qualifying assets to his or her child on or after 1 January 2025, and the market value of the qualifying assets is €10,000,000 or less, relief shall be given in respect of the capital gains tax chargeable on any gain accruing on the disposal;

(v) where an individual who has attained the age of 55 years but has not attained the age of 70 years disposes of the whole or part of his or her qualifying assets to his or her child on or after 1 January 2025, and the market value of the qualifying assets is greater than €10,000,000, relief shall be given in respect of the capital gains tax chargeable on any gain accruing on the disposal as if the consideration for the disposal had been €10,000,000;

(vi) where an individual who has attained the age of 70 years disposes of the whole or part of his or her qualifying assets to his or her child on or after 1 January 2025 and the market value of the qualifying assets is €3,000,000 or less, relief shall be given in respect of the capital gains tax chargeable on any gain accruing on the disposal;

(vii) where an individual who has attained the age of 70 years disposes of the whole or part of his or her qualifying assets to his or her child on or after 1 January 2025 and the market value of the qualifying assets is greater than €3,000,000, relief shall be given in respect of the capital gains tax chargeable on any gain accruing on the disposal as if the consideration for the disposal had been €3,000,000.”,

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

“(2) (a) Where an individual who, having attained the age of 66 years, disposes of qualifying assets to his or her child in the period commencing on 1 January 2014 and ending on 31 December 2024, the consideration for each such disposal shall be aggregated for the purposes of subparagraphs (iia) and (iii) of subsection (1)(b).

(b) Where an individual who, having attained the age of 66 years, disposes of qualifying assets to his or her child—

(i) in the period commencing on 1 January 2014 and ending on 31 December 2024, and

(ii) on or after 1 January 2025,

then, the consideration for all such disposals shall be aggregated for the purposes of subparagraphs (iv), (v), (vi) and (vii) of subsection (1)(b), provided that, where the consideration so aggregated for such disposals in the period referred to in subparagraph (i) of this paragraph is greater than €3,000,000, the consideration that shall be so aggregated in respect of such disposals in that period shall be €3,000,000.

(c) Where an individual who, having attained the age of 55 years, disposes of qualifying assets to his or her child on or after 1 January 2025, then, the consideration for each such disposal shall be aggregated for the purposes of subparagraphs (iv), (v), (vi) and (vii) of subsection (1)(b).”,

(i) by the substitution for all of the words from and including “Where” down to and including “her child” of the following:

“(a) Where an individual—

(i) who, having attained the age of 66 years—

(I) disposes of shares or securities of a family company to his or her child in the period commencing on 1 January 2014 and ending on 31 December 2024, or

(II) disposes of shares or securities of a family company to his or her child—

(A) in the period commencing on 1 January 2014 and ending on 31 December 2024, and

(B) on or after 1 January 2025,

(ii) who, having attained the age of 55 years, disposes of shares or securities of a family company to his or her child on or after 1 January 2025,”,

and

(ii) in paragraph (b), by the insertion of “there is” before “a disposal”,

and

(d) by the insertion of the following subsection after subsection (7):

“(8) A claim for relief under this section shall be made by the individual making the claim in the return required to be delivered by that individual under Chapter 3 of Part 41A for the relevant year of assessment.”.

51. Amendment of section 604A of Principal Act (relief for certain disposals of land or buildings)

51. (1) Section 604A of the Principal Act is amended—

(a) in subsection (2)—

(i) in paragraph (a)—

(I) by the insertion of “, notwithstanding any provision in the Capital Gains Tax Acts fixing the amount of the consideration deemed to be received on a disposal or given on acquisition” after “which”,

(II) in subparagraph (i), by the substitution of “purchased” for “acquired”, and

(III) in subparagraph (ii), by the substitution of “purchased” for “acquired”,

and

(ii) in paragraph (b), by the substitution of “purchased” for “acquired”,

(b) in subsection (2A), by the substitution of “purchased” for “acquired”, and

(2) Subsection (1) shall be deemed to have effect in relation to disposals made on or after 1 January 2018.

PART 2 Excise

52. Amendment of Schedule 2 to Finance Act 1999 (rates of mineral oil tax)

52. The Finance Act 1999 is amended with effect as on and from 11 October 2023 by the substitution of the following Schedule for Schedule 2 (amended by section 4 of the Finance Act 2023):

“SCHEDULE 2

With effect as on and from:	Light Oil: Rates per 1,000 litres		Heavy Oil: Rates per 1,000 litres						Liquefied Petroleum Gas: Rates per 1,000 litres		Vehicle gas: Rate per megawatt hour at gross calorific value
Petrol	Aviation gasoline	Used as a propellant	Used for air navigation	Used for private pleasure navigation	Kerosene used other than as a propellant	Fuel oil	Other heavy oil	Used as a propellant	Other liquefied petroleum gas
10 March 2022	€474.11	€474.11	€413.51	€413.51	€413.51	€84.84	€118.01	€120.55	€118.27	€54.68	€9.36
1 April 2022	€465.98	€465.98	€405.38	€405.38	€405.38	€84.84	€118.01	€120.55	€118.27	€54.68	€9.36
1 May 2022	€465.98	€465.98	€405.38	€405.38	€405.38	€103.83	€141.12	€111.14	€130.52	€66.93	€9.36
12 October 2022	€483.34	€483.34	€425.45	€425.45	€425.45	€103.83	€141.12	€111.14	€130.52	€66.93	€9.36
1 May 2023	€483.34	€483.34	€425.45	€425.45	€425.45	€122.83	€164.23	€131.47	€142.76	€79.17	€9.36
1 June 2023	€532.12	€532.12	€466.10	€466.10	€466.10	€122.83	€164.23	€140.28	€142.76	€79.17	€9.36
1 September 2023	€589.03	€589.03	€506.75	€506.75	€506.75	€122.83	€164.23	€149.09	€142.76	€79.17	€9.36
11 October 2023	€606.39	€606.39	€526.83	€526.83	€526.83	€122.83	€164.23	€149.09	€142.76	€79.17	€9.36
1 April 2024	€638.91	€638.91	€551.22	€551.22	€551.22	€122.83	€164.23	€163.96	€142.76	€79.17	€9.36
1 May 2024	€638.91	€638.91	€551.22	€551.22	€551.22	€141.82	€187.34	€184.30	€155.01	€91.42	€10.13
1 August 2024	€671.43	€671.43	€575.61	€575.61	€575.61	€141.82	€187.34	€199.17	€155.01	€91.42	€10.13
9 October 2024	€688.78	€688.78	€595.68	€595.68	€595.68	€141.82	€187.34	€199.17	€155.01	€91.42	€10.13
1 May 2025	€688.78	€688.78	€595.68	€595.68	€595.68	€160.81	€210.45	€219.50	€167.25	€103.66	€11.48
8 October 2025	€706.14	€706.14	€615.76	€615.76	€615.76	€160.81	€210.45	€219.50	€167.25	€103.66	€11.48
1 May 2026	€706.14	€706.14	€615.76	€615.76	€615.76	€179.81	€233.57	€239.83	€179.49	€115.90	€12.84
14 October 2026	€723.49	€723.49	€635.83	€635.83	€635.83	€179.81	€233.57	€239.83	€179.49	€115.90	€12.84
1 May 2027	€723.49	€723.49	€635.83	€635.83	€635.83	€198.80	€256.68	€260.16	€191.74	€128.15	€14.20
13 October 2027	€740.85	€740.85	€655.90	€655.90	€655.90	€198.80	€256.68	€260.16	€191.74	€128.15	€14.20
1 May 2028	€740.85	€740.85	€655.90	€655.90	€655.90	€217.80	€279.79	€280.49	€203.98	€140.39	€15.56
11 October 2028	€758.21	€758.21	€675.98	€675.98	€675.98	€217.80	€279.79	€280.49	€203.98	€140.39	€15.56
1 May 2029	€758.21	€758.21	€675.98	€675.98	€675.98	€236.79	€302.90	€300.83	€216.23	€152.64	€16.91
10 October 2029	€773.25	€773.25	€693.38	€693.38	€693.38	€236.79	€302.90	€300.83	€216.23	€152.64	€16.91
1 May 2030	€773.25	€773.25	€693.38	€693.38	€693.38	€253.25	€322.93	€318.45	€226.84	€163.25	€18.09

”.

53. Amendment of Schedule 2 to Finance Act 2005 (rates of tobacco products tax)

53. The Finance Act 2005 is amended with effect as on and from 11 October 2023 by the substitution of the following Schedule for Schedule 2 to that Act:

“SCHEDULE 2

(With effect as on and from 11 October 2023)

Description of Product	Rate of Tax
Cigarettes .... .... .... ....	Rate of tax at— (a) except where paragraph (b) applies, €428.48 per thousand together with an amount equal to 8.85 per cent of the price at which the cigarettes are sold by retail, or (b) €479.37 per thousand in respect of cigarettes sold by retail where the rate of tax would be less than that rate had the rate been calculated in accordance with paragraph (a).
Cigars .... .... .... ....	Rate of tax at €483.343 per kilogram.
Fine-cut tobacco for the rolling of cigarettes .... .... .... ....	Rate of tax at €465.003 per kilogram.
Other smoking tobacco .... .... .... ....	Rate of tax at €335.322 per kilogram.

”.

54. Amendment of Chapter 1 of Part 2 of, and Schedule 2 to, Finance Act 2003 (Alcohol Products Tax)

54. The Finance Act 2003 is amended—

(a) in Chapter 1 of Part 2—

(i) in section 73(2A), by the insertion of “(other than in section 78B)” after “Chapter”, and

(ii) in section 78B(2), by the substitution of “or the electronic simplified administrative document (within the meaning of Chapter 2B of Part 2 of the Finance Act 2001)” for “or the simplified accompanying document (within the meaning of Part 2 of the Finance Act 2001)”,

and

(b) with effect as on and from 1 January 2024, by the substitution of the following Schedule for Schedule 2:

“SCHEDULE 2

(With effect as on and from 1 January 2024)

Description of Product	Rate of Tax
Spirits:	€42.57 per litre of alcohol in the spirits
Beer:
Exceeding 0.5% vol but not exceeding 1.2% vol	€0.00
Exceeding 1.2% vol but not exceeding 2.8% vol	€11.27 per hectolitre per cent of alcohol in the beer
Exceeding 2.8% vol	€22.55 per hectolitre per cent of alcohol in the beer
Wine:
Still and sparkling, not exceeding 5.5% vol	€141.57 per hectolitre
Still, exceeding 5.5% vol but not exceeding 15% vol	€424.84 per hectolitre
Still, exceeding 15% vol	€616.45 per hectolitre
Sparkling, exceeding 5.5% vol	€849.68 per hectolitre
Other Fermented Beverages:
(1) Cider and Perry:
Still and sparkling, not exceeding 2.8% vol	€47.23 per hectolitre
Still and sparkling, exceeding 2.8% vol but not exceeding 6.0% vol	€94.46 per hectolitre
Still and sparkling, exceeding 6.0% vol but not exceeding 8.5% vol	€218.44 per hectolitre
Still, exceeding 8.5% vol	€424.84 per hectolitre
Sparkling, exceeding 8.5% vol	€849.68 per hectolitre
(2) Other than Cider and Perry:
Still and sparkling, not exceeding 5.5% vol	€141.57 per hectolitre
Still, exceeding 5.5% vol	€424.84 per hectolitre
Sparkling, exceeding 5.5% vol	€849.68 per hectolitre
Intermediate Beverages:
Still, not exceeding 15% vol	€424.84 per hectolitre
Still, exceeding 15% vol	€616.45 per hectolitre
Sparkling	€849.68 per hectolitre

”.

55. Amendment of section 135C of Finance Act 1992 (remission or repayment in respect of vehicle registration tax, etc.)

55. Section 135C of the Finance Act 1992 is amended—

(a) in subsection (3)(b), by the substitution of “31 December 2025” for “31 December 2023”, and

(b) in subsection (4), by the substitution of “31 December 2025” for “31 December 2023”.

56. Amendment of Part 2 of Finance Act 2001

56. The Finance Act 2001 is amended—

(a) in section 96(1)—

(i) by the substitution of the following definition for the definition of “Commission Regulation”:

“ ‘Commission Regulation’ means Commission Delegated Regulation (EU) 2022/1636 of 5 July 2022[^15];”,

and

(ii) by the insertion of the following definition:

“ ‘electronic simplified administrative document’ means the electronic simplified administrative document referred to in Article 36(1) of the Directive;”,

(b) in section 109H—

(i) in subsection (2), by the substitution of “Article 6 of the Commission Regulation” for “Article 5 of the Commission Regulation”, and

(ii) in subsection (3A)(a)(ii), by the substitution of “Article 7 of the Commission Regulation” for “Article 6(1) of the Commission Regulation”,

(i) by the substitution of “the Commission Regulation” for “Article 5 of Commission Regulation (EEC) No. 3649/92”, and

(ii) by the substitution of “electronic simplified administrative document” for “simplified accompanying document”,

(d) in section 109Q, by the deletion of the definition of “electronic simplified administrative document”,

(e) in section 109X(1), by the substitution of “electronic simplified administrative document” for “simplified accompanying document”,

(f) in section 135(1)(b)(ii), by the substitution of “simplified accompanying document, electronic simplified administrative document, or” for “simplified accompanying document, or”, and

(g) in section 153(2)(j), by the substitution of “electronic simplified administrative document” for “simplified accompanying document”.

PART 3 Value-Added Tax

57. **Interpretation (Part 3)**

57. In this Part, “Principal Act” means the Value-Added Tax Consolidation Act 2010.

58. Amendment of section 2 of Principal Act

58. Section 2 of the Principal Act is amended, in subsection (1), with effect from 1 January 2024—

(a) in the definition of “goods threshold”, by the substitution of “€80,000” for “€75,000”, and

(b) in the definition of “services threshold”, by the substitution of “€40,000” for “€37,500”.

59. Amendment of section 46 of Value-Added Tax Consolidation Act 2010

59. Section 46 of the Principal Act is amended with effect as on and from 11 October 2023, in subsection (1)(caa), by the substitution of “31 October 2024” for “31 October 2023”.

60. Repeal of section 51 of Principal Act (determination on rates and exemptions)

60. (1) Section 51 of the Principal Act is repealed.

(2) Section 120 of the Principal Act is amended, in subsection (6)—

(a) in paragraph (c), by the substitution of “section 47.” for “section 47,”, and

(b) by the deletion of paragraph (d).

61. Deposit Return Scheme

61. The Principal Act is amended—

(a) in Part 10, by the insertion of the following Chapter after section 92:

“CHAPTER 4 Deposit Return Scheme

92A. (1) In this Chapter—

‘approved body’ has the same meaning as in the Regulations of 2021;

‘deposit’ shall be construed in accordance with the Regulations of 2021;

‘deposit return scheme’ means a deposit return scheme established pursuant to Regulation 4 of the Regulations of 2021 and references to ‘scheme’ shall be construed accordingly;

‘in-scope bottle’, ‘in-scope container’ and ‘in-scope product’ have the same meaning, respectively, as in the Regulations of 2021;

‘operator’, in relation to the deposit return scheme, means an approved body that is operating the scheme;

‘Regulations of 2021’ means the Separate Collection (Deposit Return Scheme) Regulations 2021 (S.I. No. 599 of 2021);

‘tax due and payable’, means the amount of tax, calculated in accordance with regulations made under section 120(10)(l), that is due and payable in respect of a deposit.

(2) For the purposes of giving effect to Article 92 of the VAT Directive, where—

(a) a supply is made of an in-scope product, and

(b) a deposit is chargeable in accordance with the Regulations of 2021 in relation to the supply referred to in paragraph (a),

then, the taxable amount referable to the deposit shall be deemed to be reduced to nil.

(3) Notwithstanding subsection (2) and for the purposes of giving effect to Article 92 of the VAT Directive, where—

(a) a supply is made of an in-scope product,

(b) a deposit is chargeable in accordance with the Regulations of 2021 in relation to the supply referred to in paragraph (a), and

(c) the in-scope bottle or in-scope container concerned has not been returned in accordance with the Regulations of 2021,

then—

(i) the taxable amount referable to the deposit shall be the amount of that deposit, and

(ii) the operator shall be deemed to be the accountable person in respect of the tax due and payable and shall comply with the provisions of Chapter 3 of Part 9 in relation to that tax.”,

and

(b) in section 120(10)—

(i) in paragraph (k), by the substitution of “operate,” for “operate.”, and

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

“(l) the accounting for tax due and payable pursuant to section 92A in relation to the deposit return scheme (within the meaning of section 92A), including the method for calculating that tax.”.

62. Amendment of section 86 of Principal Act (special provisions for tax invoiced by flat-rate farmers)

62. Section 86 of the Principal Act is amended, in subsection (1), with effect from 1 January 2024, by the substitution of “4.8 per cent” for “5 per cent”.

63. Amendment of paragraph 6(1) of Schedule 1 to Principal Act (financial services)

63. The Principal Act is amended, in Part 2 of Schedule 1, in paragraph 6(1), in clause (a), by the deletion of “issuing,”.

64. Amendment of paragraph 11 of Schedule 1 to Principal Act (letting of immovable goods)

64. The Principal Act is amended, in Part 2 of Schedule 1, in subparagraph (1) of paragraph 11—

(a) by the substitution of “, including a letting of emergency accommodation, but excluding any of the following:” for “, but not including any of the following:”, and

(b) by the substitution of the following clause for clause (b):

“(b) supplies of the kind to which paragraph 11 of Schedule 3 relates, except where such supplies are used or to be used as emergency accommodation;”.

65. Amendment of Schedules 2 and 3 to Principal Act (zero-rated goods and services)

65. The Principal Act is amended with effect from 1 January 2024—

(a) in Part 2 of Schedule 2—

(i) in paragraph 9, by the insertion of “and audiobooks supplied on physical means of support,” after “atlases and newspapers,”, and

(ii) by the substitution of the following paragraph for paragraph 9A:

“Certain electronically supplied matter

9A. The electronic supply of books, newspapers and audiobooks, but excluding—

(a) such books, newspapers and audiobooks which are wholly or predominantly devoted to advertising or consist wholly or predominantly of video content or audible music,

(b) the items specified in subparagraphs (b) to (e) of paragraph 9, and

and

(b) in Part 2 of Schedule 3, by the substitution of the following paragraph for paragraph 7A:

“Certain electronically supplied matter

7A. The electronic supply of—

(a) periodicals,

(b) brochures, leaflets and programmes,

(d) maps, hydrographic and similar charts,

(e) children’s picture, drawing or colouring books, or

(f) music printed or in manuscript form,

but excluding the supply of any such material which is wholly or predominantly devoted to advertising or consists wholly or predominantly of audible music or video content.”.

66. Amendment of Schedule 2 to Principal Act (zero-rated goods and services)

66. Schedule 2 to the Principal Act is amended, in Part 2, in paragraph 14, by the insertion of “or buildings used wholly or predominantly for the provision of primary or post-primary education by recognised schools within the meaning of the Education Act 1998” after “private dwellings”.

PART 4 Stamp Duties

67. **Interpretation (Part 4)**

67. In this Part, “Principal Act” means the Stamp Duties Consolidation Act 1999.

68. Exemption for short-term residential leases

68. Schedule 1 to the Principal Act is amended, in the heading “LEASE.”, in paragraph (1), by the substitution of “€50,000” for “€40,000”.

69. Amendment of section 81AA of Principal Act (transfers to young trained farmers)

69. Section 81AA of the Principal Act is amended, in subsection (7A), by the substitution of “€100,000” for “€70,000”.

70. Consanguinity relief

70. Schedule 1 to the Principal Act 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 assurance.”, in paragraph (5)(a)(ii), by the substitution of “1 January 2029” for “1 January 2024”.

71. Amendment of section 101A of Principal Act (single farm payment entitlement)

71. Section 101A of the Principal Act is amended, in subsection (1), by the substitution of “Regulation (EU) 2021/2115 of the European Parliament and of the Council of 2 December 2021[^16]” for “Regulation (EU) No. 1307/2013 of the European Parliament and of the Council of 17 December 2013[^17]”.

72. Amendment of section 81C of Principal Act (further farm consolidation relief)

72. Section 81C of the Principal Act is amended, in subsection (10)(a), by the substitution of “spouse or civil partner” for “spouse” in each place where it occurs.

73. Further levy on certain financial institutions

73. The Principal Act is amended—

(a) by the insertion of the following section after section 126AA:

“Further levy on certain financial institutions

126AB. (1) In this section—

‘assessable amount’ means an amount equal to the total value of relevant deposits held by a relevant person on 31 December in the base year;

‘base year’, in respect of the year 2024, means the year 2022;

‘deposit’ and ‘eligible deposit’ have the same meaning, respectively, as they have in the European Union (Deposit Guarantee Schemes) Regulations 2015 (S. I. No. 516 of 2015);

‘due date’, in relation to a year, means 20 October in that year;

‘relevant deposit’ means a deposit which—

(a) is held by a relevant person, and

(b) is an eligible deposit;

‘relevant person’ means—

(a) Allied Irish Banks plc;

(b) EBS DAC;

(d) The Governor and Company of the Bank of Ireland.

(2) A relevant person shall, for the year 2024, not later than the due date, deliver to the Commissioners a statement showing the assessable amount.

(3) There shall be charged on every statement delivered under subsection (2) a stamp duty of an amount equal to 0.112 per cent of the assessable amount shown in the statement.

(4) The stamp duty charged by subsection (3) on a statement delivered by a relevant person under subsection (2) shall be paid by the person on delivery of the statement.

(5) In the case of failure by a relevant person—

(a) to deliver any statement required to be delivered by the person under subsection (2) by the due date, or

(b) to pay any duty chargeable on a statement referred to in paragraph (a) on the delivery of the statement,

the relevant person shall be liable to pay, in addition to the duty, interest on the duty, calculated in accordance with section 159D, for the period commencing on the due date and ending on the date on which the duty was paid.

(6) Any statement required to be delivered to the Commissioners under subsection (2) shall be delivered in such form and manner as may be specified by the Commissioners.

(7) There shall be provided to the Commissioners by a relevant person such particulars as the Commissioners may require in relation to any statement required by this section to be delivered by the person.

(8) Any duty or interest charged under this section, or any penalty applied under section 134A in relation to a statement required to be delivered under this section, shall not be allowed as a deduction for the purposes of the computation of any tax or duty under the care and management of the Commissioners that is payable by the relevant person.”,

(b) in section 126B—

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

“(1) In this section, ‘relevant person’ means a person that is required to deliver a statement to the Commissioners under a provision of this Part.”,

and

(ii) in subsection (2), by the substitution of “under a provision of this Part” for “under a specified section”,

(i) in the definition of “due date”, by the substitution of “under a provision of this Part” for “under a specified section”,

(ii) in the definition of “relevant person”, by the substitution of “under a provision of this Part.” for “under a specified section;”, and

(iii) by the deletion of the definition of “specified section”,

and

(d) in section 134A(1), in the definition of “relevant statement”, by the substitution of “a provision of Part 9” for “section 123B, 123C, 123D, 124, 124A, 124B, 125 or 125C”.

74. Amendment of Chapter 2 of Part 6 of Principal Act (special provisions relating to dematerialised securities)

74. The Principal Act is amended in Chapter 2 of Part 6—

(a) in section 78B, by the insertion of the following subsection after subsection (3):

“(4) This section shall not apply in respect of a transfer order effecting the transfer of an interest in securities through a relevant system where—

(a) the securities are dealt in on a recognised stock exchange located in the United States of America or Canada, and

(b) the relevant system is operated by a CSD located in the United States of America or Canada.”,

and

(b) by the repeal of section 78I.

75. Amendment of section 75 of Principal Act (relief for intermediaries)

75. Section 75 of the Principal Act is amended, in subsection (1), by the substitution of the following definition for the definition of “Directive”:

“ ‘Directive’ means Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014[^18] on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU;”.

76. Provisions in relation to repayment of stamp duty

76. The Principal Act is amended—

(a) in section 18, by the insertion of “, subject to section 159A,” after “the Commissioners shall”,

(b) in section 29—

(i) in subsection (4)(b), by the substitution for all of the words from and including “on an application to the Commissioners within 3 years after the date of stamping of the instrument,” down to and including “prescribed by the Minister by regulations,” of the following:

“on an application to the Commissioners within 3 years after the date of stamping of the instrument, and subject to section 159A, be repaid to the person or persons by whom the stamp duty was paid and such repayment shall bear interest calculated in accordance with section 159B”,

and

(ii) in subsection (7)—

(I) by the insertion of “and subject to section 159A,” after “was paid,”, and

(II) by the substitution of “shall bear interest calculated in accordance with section 159B” for “shall bear simple interest at the rate of 0.0161 per cent, or such other rate (if any) as stands prescribed by the Minister by regulations,”,

(c) in section 31(4), by the substitution of “shall, on an application to the Commissioners and subject to section 159A, be repaid” for “shall be returned by the Commissioners”,

(d) in section 33(2), by the insertion of “, subject to section 159A,” after “the Commissioners shall”,

(e) in section 50A(2), by the substitution of “shall, on an application to the Commissioners and subject to section 159A, be repaid by the Commissioners” for “shall be returned”,

(f) in section 53—

and

(ii) in subsection (7)—

(I) by the insertion of “and subject to section 159A,” after “was paid,”, and

(g) in section 78G(1), by the insertion of “, subject to section 159A,” after “shall”,

(h) in section 80(9), by the insertion of “subject to section 159A,” after “be acquired by the acquiring company,”—

(i) in section 81AA(11)(d), by the insertion of “, subject to section 159A,” after “then”,

(j) in section 81C(5), by the insertion of “and to section 159A” after “conditions set out in subsection (6)”,

(k) in section 83D—

(i) in subsection (8)(c), by the substitution of “declaration” for “statutory declaration”, and

(ii) in subsection (10), by the insertion of “and section 159A” after “this section”,

(l) in section 83DA(5), by the insertion of “and section 159A” after “this section”,

(m) in section 83DB(10), by the insertion of “and section 159A” after “this section”,

(n) in section 84(2), by the insertion of “, subject to section 159A,” after “shall”,

(o) in section 151(2)—

(i) in paragraph (c), by the substitution of “conveyed or transferred by that instrument, and” for “conveyed or transferred by that instrument.”, and

(ii) by the insertion of the following paragraph after paragraph (c): “(d) all of the requirements of section 159A are met.”,

(p) by the substitution of the following section for section 152:

“Repayment of overpaid stamp duty

152.

(1) In this section—

‘relevant statement’ means—

(a) an account delivered to the Commissioners under section 5, or

(b) a statement delivered to the Commissioners under Part 9;

‘return’ means an electronic return or a paper return made to the Commissioners in relation to an instrument.

(2) Where a person has made a payment of stamp duty, including any interest charged, surcharge imposed or penalty incurred, under any provision of this Act, in relation to—

(a) an instrument, or

(b) a relevant statement,

which—

(i) was not due, or

(ii) but for an error or mistake made by the person in the return to which the instrument relates or, as the case may be, in the relevant statement, would not have been due,

the person shall, on an application to the Commissioners and subject to section 159A, be entitled to a repayment of the payment concerned.”,

(q) by the substitution of the following section for section 159A:

“General provisions on claims for repayment of stamp duty

159A. (1) In this section—

‘relevant statement’ and ‘return’ have the same meaning, respectively, as in section 152;

‘repayment’ means a repayment of stamp duty including any—

(a) interest charged,

(b) surcharge imposed, or

in relation to stamp duty under any provision of this Act;

‘valid claim’ shall be construed in accordance with subsection (3).

(2) The Commissioners shall not make a repayment to a person unless—

(a) such repayment is provided for by this Act,

(b) a valid claim has been made to them for that purpose, and

(c) without prejudice to any other provision of this Act containing a shorter time limit for the making of a claim for repayment, the valid claim concerned has been made within the period of 4 years from, as the case may be—

(i) in respect of an instrument stamped by the Commissioners, the latest date the instrument was required to be stamped under section 2,

(ii) in respect of a relevant statement delivered to the Commissioners—

(I) in the case of an account delivered to the Commissioners under section 5, the latest date the account was required to be delivered to the Commissioners in accordance with the agreement entered into under that section, or

(II) in the case of a statement delivered to the Commissioners under Part 9, the latest date the statement was required to be delivered to the Commissioners under that Part,

(iii) the date the transfer order referred to in section 78B was executed,

(iv) the date the person achieved the standard within the meaning of section 81AA(11)(a),

(v) the date of acknowledgement referred to in section 83D(10)(c) in relation to a relevant residential development within the meaning of that section,

(vi) the date the condition specified in section 83DA(2)(b) is satisfied, or

(vii) the qualifying date within the meaning of section 83DB.

(3) For the purposes of this section, a claim for repayment shall be treated as a valid claim where—

(a) it is made in the form and manner specified (if any) by the provision, or provisions, of this Act under which such claim is made,

(b) all information which the Commissioners may reasonably require to enable them to determine if, and to what extent, a repayment is due, has been furnished to them, and

(c) if the claim relates to a repayment under section 152, the return or, as the case may be, the relevant statement, has been amended to reflect the correct amount of stamp duty payable, if any.

(4) Where the Commissioners determine that any of the requirements specified in subsection (2) or (3), as the case may be, have not been met in relation to a claim for repayment, they shall decide to refuse the claim for repayment and shall notify the claimant in writing of the decision and the reason or reasons for that decision.

(5) Any person aggrieved by a decision of the Commissioners under subsection (4) to refuse a claim for repayment may appeal to the Appeal Commissioners against the decision in accordance with section 949I of the Taxes Consolidation Act 1997 within the period of 30 days after the date of the notification of the decision.”,

and

(r) by the substitution of the following section for section 159B:

“Interest on repayment of stamp duty

159B. (1) In this section—

‘relevant date’, in relation to a repayment, means—

(a) the date which is 93 days after the date on which a valid claim in respect of the repayment is made to the Commissioners, or

(b) if the repayment is due to a mistaken assumption in the operation of stamp duty on the part of the Commissioners, the date which is the date of payment of the stamp duty, interest, surcharge or penalty, as the case may be, which has given rise to that repayment;

‘repayment’ has the same meaning as in section 159A;

‘valid claim’ shall be construed in accordance with section 159A(3).

(2) Subject to the provisions of this section, where a person is entitled to a repayment in accordance with any provision of this Act, the amount of the repayment shall, subject to a valid claim in respect of the repayment being made to the Commissioners, unless the contrary intention appears and subject to section 960H(4) of the Taxes Consolidation Act 1997, carry simple interest at the rate of 0.011 per cent (or such other rate (if any) prescribed by the Minister by order under subsection (5)(a)) for each day or part of a day for the period commencing on the relevant date and ending on the date upon which the repayment is made.

(3) Interest shall not be payable under this section if it would amount to €10 or less.

(4) Income tax shall not be deductible on any payment of interest under this section and such interest shall not be reckoned in computing income for the purposes of the Tax Acts.

(5) (a) The Minister may, from time to time, make an order prescribing a rate for the purposes of subsection (2).

(b) Every order made by the Minister under paragraph (a) shall be laid before Dáil Éireann as soon as may be after it is made and, if a resolution annulling the order is passed by Dáil Éireann within the next 21 days on which Dáil Éireann has sat after the order is laid before it, the order shall be annulled accordingly, but without prejudice to the validity of anything previously done under it.”.

PART 5 Capital Acquisitions Tax

77. **Interpretation (Part 5)**

77. In this Part, “Principal Act” means the Capital Acquisitions Tax Consolidation Act 2003.

78. Amendment of Schedule 2 to Principal Act (computation of tax)

78. Schedule 2 to the Principal Act is amended, in Part 1, by the substitution of the following paragraph for paragraph 9:

“9. (1) In this paragraph—

‘Child Care Regulations’ means the Child Care (Placement of Children in Foster Care) Regulations 1995 (S.I. No. 260 of 1995) or the Child Care (Placement of Children with Relatives) Regulations 1995 (S.I. No. 261 of 1995), as the case may be;

‘specified relative’, in relation to a person, means—

(a) a lineal ancestor of the person,

(b) a child of the person or of the person’s civil partner, or

(2) Where a person (referred to in this subparagraph as ‘the first-mentioned person’) has been placed in the foster care of another person (referred to in this subparagraph as ‘the second-mentioned person’) under the Child Care Regulations, the first-mentioned person is deemed to bear to the second-mentioned person the relationship of a child for the purpose of computing the tax payable on—

(a) a gift or inheritance taken by the first-mentioned person from the second-mentioned person, or

(b) a gift or inheritance taken by the first-mentioned person from a specified relative of the second-mentioned person,

where a claim is made to the Commissioners in that regard.

(3) Where two or more persons (referred to in this subparagraph as ‘the first-mentioned persons’) have been placed in the foster care of another person under the Child Care Regulations, the first-mentioned persons are deemed to bear to each other the relationship of a brother or sister, as the case may be, for the purpose of computing the tax payable on a gift or inheritance taken by any of the first-mentioned persons from any of the other first-mentioned persons, where a claim is made to the Commissioners in that regard.

(4) Where a person (referred to in this subparagraph as ‘the first-mentioned person’)—

(a) resided with another person (referred to in this subparagraph as ‘the second-mentioned person’), and

(b) was under the care of, and maintained by, the second-mentioned person at the expense of the second-mentioned person,

for periods which together comprised at least 5 years falling within the period of 18 years immediately following the birth of the first-mentioned person, the first-mentioned person is deemed to bear to the second-mentioned person the relationship of a child for the purpose of computing the tax payable on—

(i) a gift or inheritance taken by the first-mentioned person from the second-mentioned person, or

(ii) a gift or inheritance taken by the first-mentioned person from a specified relative of the second-mentioned person,

where a claim is made to the Commissioners in that regard.

(5) Where two or more persons (referred to in this subparagraph as ‘the first-mentioned persons’)—

(a) resided with another person (referred to in this subparagraph as ‘the second-mentioned person’), and

(b) were under the care of, and maintained by, the second-mentioned person at the expense of the second-mentioned person,

for periods which together comprised at least 5 years falling within the period of 18 years immediately following the birth of each of the first-mentioned persons, the first-mentioned persons are deemed to bear to each other the relationship of a brother or sister, as the case may be, for the purpose of computing the tax payable on a gift or inheritance taken by any of the first-mentioned persons from any of the other first-mentioned persons, where a claim is made to the Commissioners in that regard.”.

79. Amendment of Principal Act in relation to section 4B of Succession Act 1965

79. The Principal Act is amended—

(a) in section 2—

(i) in subsection (1)—

(I) by the deletion of the definition of “affected person”,

(II) in the definition of “child”, by the deletion of paragraph (c), and

(III) by the deletion of the definitions of “social father”, “social mother” and “social parent”,

(ii) by the deletion of subsection (1C),

(iii) in subsection (4), by the substitution of “Subject to section 2A, for the purposes of this Act” for “Subject to subsection (10), for the purposes of this Act”, and

(iv) by the deletion of subsection (10),

(b) by the insertion of the following section after section 2:

“Provisions relating to affected persons

2A. (1) In this section—

‘Act of 1965’ means the Succession Act 1965;

‘affected person’ shall be construed in accordance with section 4B(11) of the Act of 1965;

‘social father’ and ‘social mother’ have the same meaning, respectively, as they have in section 4B(12) of the Act of 1965.

(2) For the purposes of subsection (3), the relationship—

(a) between an affected person and his or her father and mother, and

(b) between an affected person and his or her social father and social mother,

shall be deduced, and all other relationships determined accordingly, in accordance with section 4B(1) of the Act of 1965.

(3) Where a person takes a benefit from a disponer to whom he or she is related by virtue of section 4B(1) of the Act of 1965 as applied by subsection (2), the person shall make an election as to whether or not the relationship that arises by virtue of the said section 4B(1) as so applied by subsection (2) shall apply for the purposes of this Act.

(4) Where a person makes an election under subsection (3) for the relationship that arises by virtue of section 4B(1) of the Act of 1965 as applied by subsection (2) to apply for the purposes of this Act, that relationship shall apply for the purposes of this Act in respect of any benefit the person takes from the same disponer.”,

and

80. Amendment of section 46 of Principal Act (delivery of returns)

80. (1) Section 46 of the Principal Act is amended—

(a) in subsection (2A)—

(i) in paragraph (a), by the substitution of “tax (if any)” for “tax”, and

(ii) in paragraph (b), by the substitution of “tax (if any)” for “tax”,

(b) in subsection (4)—

(i) in paragraph (aa), by the deletion of “or” where it occurs after “section 93(1),”, and

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

“(ab) the gift is in respect of the use or enjoyment of a specified loan to which subsection (4A) applies, or”,

“(4A) (a) In this subsection—

‘beneficial owner’, in relation to a company, means any person that is a beneficial owner of—

(i) the shares in the company, or

(ii) the entitlements under any liability incurred by the company (otherwise than for the purposes of the business of the company, wholly and exclusively);

‘close relative’, in relation to a person, means—

(i) a parent of the person,

(ii) the civil partner of a parent of the person,

(iii) a lineal ancestor of the person,

(iv) a lineal descendant of the person,

(v) a brother or sister of the person,

(vi) a brother or sister of a parent of the person, or

(vii) a brother or sister of the civil partner of a parent of the person;

‘company’ has the same meaning as in section 43;

‘loan’ means any loan, advance or any form of credit;

‘relevant period’ has the meaning given to it by section 40(1);

‘share’ has the same meaning as in section 27;

‘specified loan’, in relation to a person, means a loan made—

(i) to the person by a close relative of that person,

(ii) by a company to the person, where a beneficial owner of the company is a close relative of that person,

(iii) to a company, where the person is a beneficial owner of the company and the person making the loan is a close relative of that person, or

(iv) by a company (in this subparagraph referred to as ‘the first-mentioned company’) to another company (in this subparagraph referred to as ‘the second-mentioned company’), where the person is a beneficial owner of the second-mentioned company and a beneficial owner of the first-mentioned company is a close relative of that person;

‘tax reference number’ has the same meaning as in section 172A of the Taxes Consolidation Act 1997.

(b) This subsection shall apply to a specified loan where—

(i) a person is deemed under section 40(2) to have taken a gift in respect of the use or enjoyment of the specified loan,

(ii) within 6 months of the end of the relevant period in which the gift referred to in subparagraph (i) is so deemed to have been taken, no interest has been paid in respect of the specified loan, and

(iii) the balance outstanding on the specified loan, when aggregated with the balance outstanding on any other specified loan to which subparagraphs (i) and (ii) apply in the relevant period, exceeds €335,000 on at least 1 day in the relevant period.

(i) where any beneficial owner of a company (in this subparagraph referred to as ‘the first-mentioned company’), is itself a company (in this subparagraph referred to as ‘the second-mentioned company’), any beneficial owner of the second-mentioned company is deemed to be a beneficial owner of the first-mentioned company, and

(ii) where the shares and entitlements of a company are held in trust and have no ascertainable beneficial owners, a loan made by such a company is deemed to be made by the disponer who made the disposition under which the shares and entitlements are so held on trust, and a loan made to such a company is deemed to be made to the beneficiaries of the trust.

(d) A return to be delivered in accordance with subsection (2) shall include the following particulars in relation to each specified loan to which this subsection applies:

(i) the name, address and tax reference number of the person who made the loan;

(ii) the balance outstanding on the loan;

(iii) such other information as the Commissioners may reasonably require for the purposes of this Act.”,

and

(d) in subsection (14)—

(i) in paragraph (c), by the substitution of “disponer,” for “disponer, or”,

(ii) in paragraph (d)(ii), by the substitution of “section 93(1), or” for “section 93(1).”, and

(iii) by the insertion of the following paragraph after paragraph (d):

“(e) the gift is in respect of the use or enjoyment of a specified loan to which subsection (4A) applies.”.

(2) Subsection (1) shall come into effect on 1 January 2024.

81. Amendment of Part 10 of Principal Act (agricultural relief and business relief)

81. (1) Section 89 of the Principal Act is amended—

(a) in subsection (1)—

(i) in the definition of “agricultural property”, by the substitution of the following paragraph for paragraph (b):

“(b) a payment entitlement (within the meaning of Regulation (EU) 2021/2115 of the European Parliament and of the Council of 2 December 2021[^19]);”,

and

(ii) in the definition of “farmer”, in paragraph (b)(ii), by the substitution of “object (within the meaning of Chapter 2 of Part 3) of the trust” for “object of the trust”,

(b) in subsection (4)—

(i) in paragraph (a)—

(I) in subparagraph (i)—

(A) by the substitution of “in whole or in part, other than by way of a lease referred to in paragraph (iii) of the definition of ‘farmer’ in subsection (1),” for “or compulsorily acquired”, and

(B) by the substitution of “valuation date of the gift or inheritance or, where subsection (3) applies, the date the taxable gift or inheritance is invested in agricultural property” for “date of the gift or inheritance”,

(II) by the substitution of the following subparagraph for subparagraph (ii):

“(ii) the proceeds from such disposal are not fully expended in acquiring other agricultural property within—

(I) one year of the disposal, or

(II) where the disposal arises as a consequence of a compulsory acquisition, within 6 years of the compulsory acquisition,”,

and

(III) by the substitution of “before the property is disposed of” for “before the property is disposed of or compulsorily acquired”,

(ii) in paragraph (aa)—

(I) in subparagraph (i), by the deletion of “or compulsory acquisition” in both places where it occurs, and

(II) by the substitution of the following subparagraph for subparagraph (ii):

“(ii) the proceeds from a disposal—

(I) shall include an amount equal to the market value of the consideration (not being cash) received for the disposal, where full consideration is received for the disposal, or

(II) shall be an amount equal to the market value of the agricultural property immediately before the disposal, where less than full consideration is received for the disposal.”,

“(4B) Where a donee, successor or lessee ceases to qualify as a farmer, because he or she no longer satisfies the conditions specified in paragraph (i), (ii) or (iii), as the case may be, of the definition of ‘farmer’ in subsection (1), within the period of 6 years commencing on the valuation date of the gift or inheritance, or, where subsection (3) applies, the date the taxable gift or inheritance is invested in agricultural property, all or, as the case may be, part of the agricultural property shall for the purposes of subsection (2), otherwise than on the death of the donee, successor or lessee, be treated as property comprised in the gift or inheritance that is not agricultural property, and the taxable value of the gift or inheritance shall be determined accordingly and tax shall be payable accordingly.”,

and

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

“(4C) Where, pursuant to subsection (4)(a) or (4B), as the case may be, all or part of the property comprised in a gift or inheritance is to be treated as property that is not agricultural property then, by virtue of the return delivered in respect of the gift or inheritance being defective in a material respect, an additional return shall be delivered to the Commissioners, and any outstanding tax paid, in accordance with section 46(9).”.

(2) Section 101 of the Principal Act is amended—

(a) in subsection (1), by the substitution of “valuation date” for “date”,

(b) in subsection (2)(b), by the substitution of “is disposed of in whole or in part within the relevant period and is not replaced, within a year of the disposal,” for “is sold, redeemed or compulsorily acquired within the relevant period and is not replaced, within a year of the sale, redemption or compulsory acquisition,”, and

“(3A) Where, pursuant to subsection (2), the reduction in value in respect of all or part of the property comprised in a gift or inheritance ceases to be applicable then, by virtue of the return delivered in respect of the gift or inheritance being defective in a material respect, an additional return shall be delivered to the Commissioners, and any outstanding tax paid, in accordance with section 46(9).”.

(3) Section 102A(2) of the Principal Act is amended—

(a) in subparagraph (c)—

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Finance (No. 2) Act 2023

47. Amendment of section 536 of Principal Act (capital sums: receipt of compensation and insurance moneys not treated as a disposal in certain cases)

48. Amendment of section 597AA of Principal Act (revised entrepreneur relief)

49. Amendment of section 598 of Principal Act (disposals of business or farm on “retirement”)

50. Amendment of section 599 of Principal Act (disposals within family of business or farm)

51. Amendment of section 604A of Principal Act (relief for certain disposals of land or buildings)

PART 2 Excise

52. Amendment of Schedule 2 to Finance Act 1999 (rates of mineral oil tax)

53. Amendment of Schedule 2 to Finance Act 2005 (rates of tobacco products tax)

54. Amendment of Chapter 1 of Part 2 of, and Schedule 2 to, Finance Act 2003 (Alcohol Products Tax)

55. Amendment of section 135C of Finance Act 1992 (remission or repayment in respect of vehicle registration tax, etc.)

56. Amendment of Part 2 of Finance Act 2001

PART 3 Value-Added Tax

57. Interpretation (Part 3)

58. Amendment of section 2 of Principal Act

59. Amendment of section 46 of Value-Added Tax Consolidation Act 2010

60. Repeal of section 51 of Principal Act (determination on rates and exemptions)

61. Deposit Return Scheme

“CHAPTER 4 Deposit Return Scheme

62. Amendment of section 86 of Principal Act (special provisions for tax invoiced by flat-rate farmers)

63. Amendment of paragraph 6(1) of Schedule 1 to Principal Act (financial services)

64. Amendment of paragraph 11 of Schedule 1 to Principal Act (letting of immovable goods)

65. Amendment of Schedules 2 and 3 to Principal Act (zero-rated goods and services)

66. Amendment of Schedule 2 to Principal Act (zero-rated goods and services)

PART 4 Stamp Duties

67. Interpretation (Part 4)

68. Exemption for short-term residential leases

69. Amendment of section 81AA of Principal Act (transfers to young trained farmers)

70. Consanguinity relief

71. Amendment of section 101A of Principal Act (single farm payment entitlement)

72. Amendment of section 81C of Principal Act (further farm consolidation relief)

73. Further levy on certain financial institutions

74. Amendment of Chapter 2 of Part 6 of Principal Act (special provisions relating to dematerialised securities)

75. Amendment of section 75 of Principal Act (relief for intermediaries)

76. Provisions in relation to repayment of stamp duty

PART 5 Capital Acquisitions Tax

77. Interpretation (Part 5)

78. Amendment of Schedule 2 to Principal Act (computation of tax)

79. Amendment of Principal Act in relation to section 4B of Succession Act 1965

80. Amendment of section 46 of Principal Act (delivery of returns)

81. Amendment of Part 10 of Principal Act (agricultural relief and business relief)

57. **Interpretation (Part 3)**

67. **Interpretation (Part 4)**

77. **Interpretation (Part 5)**