FINANCE ACT 2025

Type Act

Publication 2025-12-23

State In force

Text As published

Source Irish Statute Book

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articles 107

This is the act as published. Later amendments are not folded into the text below: each one is a separate act in this repository and an entry in this law's history.

Act to provide for the imposition, repeal, remission, alteration and regulation of taxation, of stamp duties and of duties relating to excise and otherwise to make further provision in connection with finance; and to provide for related matters.

Reform history JSON API

An Act to provide for the imposition, repeal, remission, alteration and regulation of taxation, of stamp duties and of duties relating to excise and otherwise to make further provision in connection with finance; and to provide for related matters.

[23rd December, 2025]

Be it enacted by the Oireachtas as follows:

Chapter 1 Interpretation

1. **Definition (Part 1)**

1. In this Part, “Principal Act” means the Taxes Consolidation Act 1997.

2. Amendment of section 531AN of Principal Act (rate of charge)

2. (1) Section 531AN of the Principal Act is amended—

(a) in subsection (3), by the substitution of “€28,700” for “€27,382”,

(b) in subsection (4), by the substitution of “2028” for “2026”, and

“PART 1

Part of aggregate income (1) Rate of universal social charge (2)

The first €12,012 0.5 per cent

The next €16,688 2 per cent

The next €41,344 3 per cent

The remainder 8 per cent

”.


Part of aggregate income (1)	Rate of universal social charge (2)
The first €12,012	0.5 per cent
The next €16,688	2 per cent
The next €41,344	3 per cent
The remainder	8 per cent

(2) Subsection (1) applies for the year of assessment 2026 and each subsequent year of assessment.

Chapter 3 Income Tax

3. Amendment of section 473B of Principal Act (rent tax credit)

3. Section 473B of the Principal Act is amended by the substitution of the following subsection for subsection (14):

“(14) This section shall apply in respect of the years of assessment 2022 to 2028 (both years inclusive).”.

4. Amendment of section 473C of Principal Act (mortgage interest tax relief)

4. Section 473C of the Principal Act is amended—

(a) in subsection (1)—

(i) by the substitution of the following definition for the definition of “qualifying period”:

“ ‘qualifying period’ means—

(a) for the purposes of subsection (4), the period commencing on 1 January 2023 and ending on 31 December 2023,

(b) for the purposes of subsection (4A), the period commencing on 1 January 2024 and ending on 31 December 2024,

(c) for the purposes of subsection (4B), the period commencing on 1 January 2025 and ending on 31 December 2025, and

(d) for the purposes of subsection (4C), the period commencing on 1 January 2026 and ending on 31 December 2026;”,

(ii) by the substitution of the following definition for the definition of “relievable interest”:

“ ‘relievable interest’ has the meaning given to it—

(a) by subsection (4), in the case of the year of assessment 2023,

(b) by subsection (4A), in the case of the year of assessment 2024,

(c) by subsection (4B), in the case of the year of assessment 2025, and

(d) by subsection (4C), in the case of the year of assessment 2026;”,

and

(iii) by the substitution of the following definition for the definition of “upper limit”:

“ ‘upper limit’ means—

(a) €6,250 for the years of assessment 2023, 2024 and 2025,

(b) €3,125 for the year of assessment 2026, or

(c) where subsection (5), (5A), (5B) or (5C) apply, the amount determined in accordance with paragraph (a)(i), (a)(ii) or (b), as the case may be, of the subsection concerned.”,

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

“(4B)

(a) For the purposes of this section, in respect of a claim under subsection (2) for the year of assessment 2025, relievable interest, in relation to an individual, shall be an amount determined by the formula—

A – B

where—

A is the amount of qualifying interest for the year of assessment 2025, and

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

(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—

(i) where the number of days in the year of assessment to which ‘A’ relates is greater than the number of days in the year of assessment to which ‘B’ relates, be determined by the following formula—

A x D/E

and

(ii) where the number of days in the year of assessment to which ‘B’ relates is greater than the number of days in the year of assessment to which ‘A’ relates, be determined by the following formula—

B x D/E

where—

D is the number of days in the year of assessment with the lesser number of days, and

E is the number of days in the year of assessment with the greatest number of days.

(4C)

(a) For the purposes of this section, in respect of a claim under subsection (2) for the year of assessment 2026, relievable interest, in relation to an individual, shall be an amount determined by the formula—

(A – B) x 50 per cent

where—

A is the amount of qualifying interest for the year of assessment 2026, and

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

(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—

(i) where the number of days in the year of assessment to which ‘A’ relates is greater than the number of days in the year of assessment to which ‘B’ relates, be determined by the following formula—

A x D/E

and

(ii) where the number of days in the year of assessment to which ‘B’ relates is greater than the number of days in the year of assessment to which ‘A’ relates, be determined by the following formula—

B x D/E

where—

D is the number of days in the year of assessment with the lesser number of days, and

E is the number of days in the year of assessment with the greatest number of days.”,

(d) by the insertion of the following subsections after subsection (5A):

“(5B) Where, for the year of assessment 2025, qualifying interest referred to in subsection (4B) is for a period of less than 365 days, then—

(a) where—

(i) the number of days in the year of assessment to which ‘A’ in the formula in subsection (4B) relates is less than 365 and the number of days in the year of assessment to which ‘B’ in the formula in subsection (4B) relates is equal to 365, or

(ii) the number of days in the year of assessment to which ‘B’ in the formula in subsection (4B) relates is less than 365 and the number of days in the year of assessment to which ‘A’ in the formula in subsection (4B) relates is equal to 365,

the upper limit shall be determined by the formula—

F x G/H

or

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

F x I/J

where—

F is €6,250,

G is the number of days in the year of assessment with the lesser number of days,

H is the number of days in the year of assessment with the greater number of days,

I is the number of days in the year of assessment with the lesser number of days, and

J is 365 days.

(5C) Where, for the year of assessment 2026, qualifying interest referred to in subsection (4C) is for a period of less than 365 days, then—

(a) where—

(i) the number of days in the year of assessment to which ‘A’ in the formula in subsection (4C) relates is less than 365 and the number of days in the year of assessment to which ‘B’ in the formula in subsection (4C) relates is equal to 365, or

(ii) the number of days in the year of assessment to which ‘B’ in the formula in subsection (4C) relates is less than 365 and the number of days in the year of assessment to which ‘A’ in the formula in subsection (4C) relates is equal to 365,

the upper limit shall be determined by the formula—

F x G/H

or

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

F x I/J

where—

F is €3,125,

G is the number of days in the year of assessment with the lesser number of days,

H is the number of days in the year of assessment with the greater number of days,

I is the number of days in the year of assessment with the lesser number of days, and

J is 365 days.”,

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

(f) in subsection (8)(a), by the substitution of “the calendar year 2023, 2024, 2025 or 2026, as the case may be,” for “the calendar year 2023 or 2024, as the case may be,”,

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

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

“(i) the qualifying interest paid by the claimant for—

(I) the year of assessment 2022,

(II) the qualifying period referred to in paragraph (a) of the definition, in subsection (1), of that term to which the claim relates,

(III) the qualifying period referred to in paragraph (b) of the definition, in subsection (1), of that term to which the claim relates,

(IV) the qualifying period referred to in paragraph (c) of the definition, in subsection (1), of that term to which the claim relates, or

(V) the qualifying period referred to in paragraph (d) of the definition, in subsection (1), of that term to which the claim relates,

(ii) where subsection (9)(b) applies, the total qualifying interest paid by all of the individuals concerned for—

(I) the year of assessment 2022,

(II) the qualifying period referred to in paragraph (a) of the definition, in subsection (1), of that term to which the claim relates,

(III) the qualifying period referred to in paragraph (b) of the definition, in subsection (1), of that term to which the claim relates,

(IV) the qualifying period referred to in paragraph (c) of the definition, in subsection (1), of that term to which the claim relates, or

(V) the qualifying period referred to in paragraph (d) of the definition, in subsection (1), of that term to which the claim relates, and”.

5. Amendment of section 477C of Principal Act (Help to Buy)

5. Section 477C of the Principal Act is amended, with effect as on and from 26 November 2025, in subparagraph (ii) of the definition in subsection (1) of “qualifying residence”, by the substitution of “paragraph (c) or (cac), as the case may be, of section 46(1)” for “section 46(1)(c)”.

6. Amendment of section 204B of Principal Act (exemption in respect of compensation for certain living donors)

6. Section 204B of the Principal Act is amended by the substitution of “subsections (3) and (4) of section 12 of the Human Tissue (Transplantation, Post-Mortem, Anatomical Examination and Public Display) Act 2024” for “Regulation 21(2) of the European Union (Quality and Safety of Human Organs Intended for Transplantation) Regulations 2012 (S.I. No. 325 of 2012)”.

7. Amendment of section 208B of Principal Act (charities - miscellaneous)

7. Section 208B of the Principal Act is amended by the insertion of the following subsection after subsection (3):

“(3A)

(a) An exemption under section 207 or 208, as the case may be, shall apply from the date of the notice of the determination under section 864, on a claim under section 207 or 208, granting the exemption.

(b) An exemption under section 208A shall apply from the date of the notice of the determination under that section granting the exemption.”.

8. Amendment of section 235 of Principal Act (bodies established for promotion of athletic or amateur games or sports)

8. Section 235(2) of the Principal Act is amended by the insertion of “, and the exemption shall apply from the date of the notice of the determination under section 864 on a claim, under this section, granting the exemption” after “subsection (1)(a)”.

9. Amendment of section 847A of Principal Act (donations to certain sports bodies)

9. Section 847A of the Principal Act is amended—

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

“ ‘approved project number’ has the meaning given to it by subsection (4)(aa);

‘unique receipt number’ has the meaning given to it by subsection (16)(b)(vii).”,

(b) in subsection (4), by the insertion of the following paragraph after paragraph (a):

“(aa) Where the Minister gives a certificate to a body in respect of a project under paragraph (a), the Minister shall assign a unique number to the project (in this section referred to as an ‘approved project number’) and include that number in the certificate.”,

(i) by the substitution of the following paragraph for paragraph (b):

“(b) For the purposes of paragraph (a)(i), any such deduction or set-off shall not be taken into account in determining in respect of the individual or, as the case may be, the individual’s spouse or civil partner—

(i) the remuneration of the office or employment for the purposes of section 774(7)(c) of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment, or

(ii) net relevant earnings within the meaning of section 787, 787B or 787X, as the case may be, of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment,”,

and

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

“(f) An election made under paragraph (a) is irrevocable with effect from the date that is the earliest of—

(i) the specified return date for the chargeable period, within the meaning of section 959A, in respect of the return referred to in paragraph (d),

(ii) the date on which the return referred to in paragraph (d) is delivered, or

(iii) 1 December in the year following the year in which the relevant donation was made.”,

(d) in subsection (11)—

(i) by the substitution of the following paragraph for paragraph (b):

“(b) For the purposes of paragraph (a)(i), any such deduction or set-off shall not be taken into account in determining, in respect of the individual or, as the case may be, the individual’s spouse or civil partner—

(i) the remuneration of the office or employment for the purposes of section 774(7)(c) of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment, or

(ii) net relevant earnings within the meaning of section 787, 787B or 787X, as the case may be, of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment.”,

(ii) in paragraph (d)—

(I) in subparagraph (ii), by the substitution of “in subsection (16),” for “in subsection (16), and”, and

(II) by the insertion of the following subparagraphs after subparagraph (ii):

“(iia) the approved project number,

(iib) the unique receipt number, and”,

and

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

“(f) An election made under paragraph (a) is irrevocable with effect from the date that is the earlier of—

(i) the date on which a claim is made under paragraph (d), or

(ii) 1 December in the year following the year in which the relevant donation was made.”,

(e) in subsection (12), by the substitution of “subsection (9)(a)(ii)(II) or subsection (11)(a)(ii)(II), as the case may be,” for “subsection (11)(b)”, and

(f) in subsection (16)(b)—

(i) in subparagraph (v), by the substitution of “issued,” for “issued, and”, and

(ii) by the insertion of the following subparagraphs after subparagraph (vi):

“(vii) a unique number assigned by the approved sports body in respect of the relevant donation (in this section referred to as a “unique receipt number”), and

(viii) the approved project number,”.

10. Section 531AM of the Principal Act is amended, in paragraph (b)(viii)(II) of the Table to that section—

(a) in subclause (D), by the deletion of “or”, and

(b) by the insertion of the following subclause after subclause (D):

“(DA) under section 847AA in respect of a relevant donation (within the meaning of that section), or”.

11. Amendment of section 847AA of Principal Act (deduction for donations to National Governing Bodies)

11. Section 847AA of the Principal Act is amended—

(a) in subsection (1)—

(i) in the definition of “elite athlete”, by the insertion of “or” after “Sport Ireland International Carding Scheme,”,

(ii) in paragraph (a)(ii) of the definition of “national governing body”, by the substitution of “Minister,” for “Minister for Tourism, Culture, Arts, Gaeltacht, Sports and Media,”, and

(iii) by the insertion of the following definitions:

“ ‘qualifying project number’ has the meaning given to it by subsection (8)(aa);

‘unique receipt number’ has the meaning given to it by subsection (9).”,

(b) in subsection (4)—

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

“(c) For the purposes of paragraph (a)(i), any such deduction or set-off shall not be taken into account in determining in respect of the individual or, as the case may be, the individual’s spouse or civil partner—

(i) the remuneration of the office or employment for the purposes of section 774(7)(c) of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment, or

(ii) net relevant earnings within the meaning of section 787, 787B or 787X, as the case may be, of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment.”,

(ii) in paragraph (e)—

(I) in subparagraph (ii), by the substitution of “in subsection (9),” for “in subsection (9) and”,

(II) by the insertion of the following subparagraphs after subparagraph (ii):

“(iia) the qualifying project number,

(iib) the unique receipt number, and”,

and

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

“(g) An election made under paragraph (a) is irrevocable from the date that is the earlier of—

(i) the date on which the claim referred to in paragraph (e) is made, or

(ii) 1 December in the year following the year in which the relevant donation was made.”,

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

“(c) For the purposes of paragraph (a)(i), any such deduction or set-off shall not be taken into account in determining in respect of the individual or, as the case may be, the individual’s spouse or civil partner—

(i) the remuneration of the office or employment for the purposes of section 774(7)(c) of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment, or

(ii) net relevant earnings, within the meaning of section 787, 787B or 787X, as the case may be, of the individual or, as the case may be, the individual’s spouse or civil partner for the relevant year of assessment.”,

and

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

“(g) An election made under paragraph (a) is irrevocable from the date that is the earliest of—

(i) the specified return date for the chargeable period, within the meaning of section 959A, in respect of the return referred to in paragraph (e),

(ii) the date on which the return referred to in paragraph (e) is delivered, or

(iii) 1 December in the year following the year in which the relevant donation was made.”,

(d) in subsection (8), by the insertion of the following paragraph after paragraph (a):

“(aa) Where the Minister gives a certificate to a body in respect of a project under paragraph (a), the Minister shall assign a unique number to the project (in this section referred to as a ‘qualifying project number’) and shall include that number in the certificate.”,

and

(e) in subsection (9)—

(i) by the substitution of “shall, on the acceptance of a relevant donation, assign a unique number to the donation (in this section referred to as a ‘unique receipt number’) and give to the person” for “shall, on acceptance of a relevant donation, give to the person”, and

(ii) in paragraph (b)—

(I) in subparagraph (iv), by the deletion of “and”, and

(II) in subparagraph (v), by the deletion of “and”, and

(III) by the insertion of the following subparagraphs after subparagraph (v):

“(vi) the qualifying project number, and

(vii) the unique receipt number, and”.

12. Amendment of section 216D of Principal Act (certain profits of micro-generation of electricity)

12. Section 216D of the Principal Act is amended, in subsection (1), in the definition of “relevant period”, by the substitution of “31 December 2028” for “31 December 2025”.

13. Amendment of section 216F of Principal Act (exemption of certain profits arising from production, maintenance and repair of certain musical instruments)

13. Section 216F(1) of the Principal Act is amended by the substitution of the following definition for the definition of “relevant period”:

“ ‘relevant period’ means any of the years of assessment 2023 to 2028 (both years inclusive);”.

14. Annual returns by qualifying fund managers

14. (1) Part 30 of the Principal Act is amended by the insertion of the following section after section 784B:

“784BA. (1) In this section—

‘electronic means’ has the same meaning as it has in section 917EA;

‘fund holder’ means the individual beneficially entitled to the assets in the approved retirement fund;

‘qualifying fund manager’ has the same meaning as it has in section 784A;

‘tax reference number’ has the same meaning as it has in section 784A.

(2) A qualifying fund manager shall, within 3 months of the end of the year of assessment, make a return to the Revenue Commissioners, by electronic means, in respect of all approved retirement funds which the qualifying fund manager administered in that year of assessment.

(3) For the purposes of a return under this section, the qualifying fund manager shall provide to the Revenue Commissioners the following information in respect of each approved retirement fund that the qualifying fund manager administers:

(a) the name and address of the fund holder;

(b) the tax reference number of the fund holder;

(c) the date on which the approved retirement fund was first held by the fund holder;

(d) the country of residence of the fund holder;

(e) the number of approved retirement funds administered by the qualifying fund manager on behalf of each fund holder;

(f) details and value of the assets held in the approved retirement fund, including:

(i) asset type and location;

(ii) details of any income, profits or chargeable gains derived from those assets during the year of assessment concerned;

(iii) details of any assets acquired and or disposed of during the year of assessment concerned;

(iv) details of any distributions made in the year of assessment to which the return relates;

(g) in respect of a transaction deemed to be a distribution for the purposes of this Chapter:

(i) the name and address of the person to whom the distribution was made;

(ii) the amount of the distribution;

(iii) the tax which the qualifying fund manager is required to account for in relation to that distribution;

(h) such other information in relation to assets held in, and distributions made from, the approved retirement fund as the Revenue Commissioners may require for the purposes of this section.

(4) A return under this section shall be in a form prescribed or authorised by the Revenue Commissioners and shall include a declaration to the effect that the return is correct and complete.

(5) A person who is required to make a return under this section and who—

(a) fails to comply with any of the requirements of subsections (2) or (3), as the case may be, or

(b) makes an incorrect or incomplete return under this section,

shall, for each such failure, be liable to a penalty of €3,000.”.

(2) Subsection (1) applies for the year of assessment 2026 and each subsequent year of assessment.

15. Repeal of section 14 of Finance Act 2024

15. Section 14 of the Finance Act 2024 is repealed.

16. Automatic enrolment retirement savings system

16. Part 30 of the Principal Act is amended by the insertion of the following Chapter after Chapter 2D:

“CHAPTER 2E

AUTOMATIC ENROLMENT RETIREMENT SAVINGS SYSTEM

Interpretation (Chapter 2E)

787AE. In this Chapter—

‘Act of 2024’ means the Automatic Enrolment Retirement Savings System Act 2024;

‘AE provider scheme’ has the same meaning as it has in the Act of 2024;

‘Authority’ has the same meaning as it has in the Act of 2024;

‘balance’ has the same meaning as it has in Part 5 of the Act of 2024;

‘contributing participant’ has the same meaning as it has in the Act of 2024;

‘contribution’ has the same meaning as it has in the Act of 2024;

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

‘employee’ has the same meaning as it has in Chapter 4 of Part 42;

‘employer’ has the same meaning as it has in Chapter 4 of Part 42;

‘employer contribution’ has the same meaning as it has in the Act of 2024;

‘participant’ has the same meaning as it has in the Act of 2024;

‘participant account’, in relation to a participant, means the account maintained for the participant by the Authority under section 76 of the Act of 2024;

‘personal representative’ has the same meaning as it has in Part 5 of the Act of 2024;

‘State contribution’ has the same meaning as it has in the Act of 2024;

‘unit’, in relation to an AE provider scheme, has the same meaning as it has in Part 4 of the Act of 2024.

Allowance to employer

787AF. (1) For the purposes of this section, ‘chargeable period’ means an accounting period of a company or a year of assessment.

(2) Subject to subsection (3), any employer contribution in respect of a contributing participant shall, for the purposes of Case I or II of Schedule D and of sections 83 and 707(4), be allowed to be deducted as an expense, or expense of management, incurred in the chargeable period in which the sum is paid but no other sum shall for those purposes be allowed to be deducted as an expense, or expense of management, in respect of the making, or any provision for the making, of any such contributions.

(3) The amount of an employer contribution which may be deducted under subsection (2) shall not exceed the amount contributed by that employer to the Authority in respect of an employee in a trade or undertaking in respect of the profits of which the employer is assessable to income tax or corporation tax, as the case may be.

Repayments to employer

787AG. Where a repayment of employer contributions is made or becomes due to an employer under section 64 of the Act of 2024 as a result of an overpayment of contributions to the Authority, the repayment shall be treated for the purposes of the Tax Acts as a receipt of that trade or undertaking receivable when the repayment is due or on the last day on which the trade or undertaking is carried on by the employer, whichever is the earlier.

Exemption of AE provider schemes

787AH. (1) Exemption from income tax shall, on a claim being made in that behalf, be allowed in respect of income derived from investments or deposits of assets held in an AE provider scheme if it is income from investments or deposits held for the purposes of the scheme.

(2)

(a) In this subsection, ‘financial futures’ and ‘traded options’ mean, respectively, financial futures and traded options for the time being dealt in or quoted on any futures exchange or any stock exchange, whether or not that exchange is situated in the State.

(b) For the purposes of subsection (1), a contract entered into in the course of dealing in financial futures or traded options shall be regarded as an investment.

(3) Exemption from income tax shall, on a claim being made in that behalf, be allowed in respect of underwriting commissions if the underwriting commissions are applied for the purposes of the AE provider scheme and in respect of which the Authority would, but for this subsection, be chargeable to tax under Case IV of Schedule D.

(4)

(a) A unit in an AE provider scheme is not an asset of a pension fund for the purposes of Chapter 1A of Part 27.

(b) For the purpose of this subsection, a unit referred to in paragraph (a) includes a unit (within the meaning of section 739B) in an investment undertaking (within the said meaning) held by a participant.

Taxation of payments from automatic enrolment retirement savings system

787AI. (1) Subject to subsections (2) and (3)—

(a) the payment of the balance from a participant account, after any lump sum withdrawn in accordance with subsection (3)(a), shall, notwithstanding anything in section 18 or 19, be treated as a payment to the participant of emoluments to which Schedule E applies and, accordingly, the provisions of Chapter 4 of Part 42 shall apply to any such payment or amount treated as a payment, and

(b) the Authority shall deduct tax from the balance held in that participant’s account at the higher rate for the year of assessment in which the balance is made available unless the Authority has received from the Revenue Commissioners a revenue payroll notification (within the meaning of section 983) for that year in respect of the participant.

(2) The Authority shall be liable to pay to the Collector-General the income tax which the Authority is required to deduct from any balance withdrawn by a participant by virtue of this section and the individual beneficially entitled to the balance withdrawn by that participant from their participating account, including the personal representatives of a deceased individual who was so entitled prior to the individual’s death, shall allow such deduction; but where there are no funds or insufficient funds available out of which the Authority may satisfy the tax required to be deducted, the amount of such tax for which there are insufficient funds available shall be a debt due to the Authority from the individual beneficially entitled to the balance held in the participant account or from the estate of the deceased individual, as the case may be.

(3) Subsection (1) shall not apply where the balance from a participant account is—

(a) an amount made available, at the time the balance of the participant account is first made available to the participant, by way of lump sum (in accordance with section 83(1)(a) of the Act of 2024) not exceeding 25 per cent of the value of the balance at that time, or

(b) an amount made available to the personal representatives of the participant following the death of the participant and before the giving of a notification under section 82(1)(d) of the Act of 2024 by the Authority.

(4)

(a) Where the payment of the balance referred to in subsection (1) is made following the death of the participant who was prior to death beneficially entitled to the assets of the participant account, the amount of the funds shall be treated as the income of that participant for the year of assessment in which that participant dies and, subject to paragraph (b), subsection (1) shall apply accordingly.

(b) Subsection (1) shall not apply to a payment made of the balance following the death of the participant, where the giving of a notification under section 82(1)(d) of the Act of 2024 by the Authority is made to—

(i) a spouse or civil partner of the participant, or

(ii) any child of the participant or any child of the spouse or civil partner of the participant.

(c) Where, in a case referred to in paragraph (b), the payment of the balance is made to a person who had attained the age of 21 years at the date of death of the participant beneficially entitled to the assets in the participant account, the Authority shall deduct income tax from the distribution under Case IV of Schedule D at a rate of 30 per cent, and—

(i) the amount so charged to tax—

(I) shall not be reckoned in computing total income for the purposes of the Tax Acts, and

(II) shall be computed without regard to any amount deductible from, or deductible in computing, total income for the purposes of the Tax Acts,

(ii) the charging of the balance in such manner shall be without any relief or reduction specified in the Table to section 458, or any other deduction from that distribution, and

(iii) section 188 shall not apply as regards the amount so charged.

(d) Where the Authority deducts tax in accordance with paragraph (c), subsections (8) to (15) of section 790AA shall, with any necessary modifications, apply as if any reference in those subsections—

(i) to the administrator were a reference to the Authority, and

(ii) to an excess lump sum were a reference to the balance of a kind referred to in paragraph (c).”.

17. Repeal of section 15 of Finance Act 2024

17. Section 15 of the Finance Act 2024 is repealed.

18. Automatic enrolment retirement savings system (amendments consequential on insertion of Chapter 2E in Part 30)

18. (1) The Principal Act is amended—

(a) in section 118, by the insertion of the following subsection after subsection (5L):

“(5M) Subsection (1) shall not apply to expense incurred by the body corporate in the provision for an employee (within the meaning of Chapter 2E of Part 30) of a contribution (within the said meaning).”,

(b) in Part 7, by the insertion of the following section after section 192P:

“Exemption in respect of State contribution under automatic enrolment retirement savings system

192Q. A State contribution (within the meaning of the Automatic Enrolment Retirement Savings System Act 2024) shall be exempt from income tax and shall not be reckoned in computing total income for the purposes of the Income Tax Acts or in computing amounts chargeable to universal social charge in accordance with Part 18D.”,

(i) in paragraph (i), by the substitution of “such subsidiary,” for “such subsidiary, or”,

(ii) in paragraph (j), by the substitution of “such subsidiary,” for “such subsidiary.”, and

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

“(k) interest paid to the Authority (within the meaning of Chapter 2E of Part 30), or

(l) interest paid by the Authority (within the meaning of Chapter 2E of Part 30).”,

(d) in section 256(1), in the definition of “relevant deposit”—

(i) in paragraph (a)—

(I) in subparagraph (v), by the substitution of “The Investor Compensation Company Limited,” for “The Investor Compensation Company Limited, or”,

(II) in subparagraph (vi), by the substitution of “Icarom plc, or” for “Icarom plc,”, and

(III) by the insertion of the following subparagraph after subparagraph (vi):

“(vii) An tÚdarás Náisiúnta um Uathrollú Coigiltis Scoir,”,

(ii) in paragraph (k), by the substitution of “Revenue Commissioners,” for “Revenue Commissioners, or”,

(iii) in paragraph (l), by the substitution of “relevant deposit taker, or” for “relevant deposit taker;”, and

(iv) by the insertion of the following paragraph after paragraph (l):

“(m) which is made by the Authority (within the meaning of Chapter 2E of Part 30) in respect of contributions (within the meaning of the Automatic Enrolment Retirement Savings System Act 2024) made to the Authority;”,

(e) in section 531AM, in paragraph (a) of the Table to that section—

(i) in clause (VI), by the deletion of “and”,

(ii) in clause (VII), by the substitution of “(within the meaning of Chapter 2D of Part 30) and,”, for “(within the meaning of Chapter 2D of Part 30).”, and

(iii) by the insertion of the following clause after clause (VII):

“(VIII) emoluments in the nature of a contribution by an employer to the Authority (within the meaning of Chapter 2E of Part 30).”,

(f) in section 608(2), by the substitution of “PEPP assets (within the meaning of Chapter 2D of Part 30) or held by or on behalf of that person as units in an AE provider scheme (within the meaning of Chapter 2E of Part 30)” for “PEPP assets (within the meaning of Chapter 2D of Part 30)”,

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

“(f) any contract with an AE provider scheme (within the meaning of Chapter 2E of Part 30);”,

(h) in section 739B(1), by the insertion of the following definitions:

“ ‘AE provider scheme’ has the same meaning as it has in Chapter 2E of Part 30;

‘Authority’ has the same meaning as it has in Chapter 2E of Part 30;

‘participant’ has the same meaning as it has in Chapter 2E of Part 30;”,

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

“(kd) holds units in an AE provider scheme, registered in the name of the Authority on behalf of a participant and the Authority has made a declaration to that effect to the investment undertaking,”,

(j) in section 787O(1)—

(i) in the definition of “administrator”—

(I) in paragraph (d), by the substitution of “section 787U,” for “section 787U, and”,

(II) in paragraph (e), by the substitution of “Chapter 2D, and” for “Chapter 2D;”, and

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

“(f) An tÚdarás Náisiúnta um Uathrollú Coigiltis Scoir;”,

(ii) in the definition of “member”, by the substitution of “Chapter 2D, a participant within the meaning of Chapter 2E” for “Chapter 2D”,

(iii) in the definition of “relevant pension arrangement”—

(I) in paragraph (f), by the substitution of “paragraph (e),” for “paragraph (e), or”,

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

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

“(h) the automatic enrolment retirement savings system established, maintained and controlled by the Authority (within the meaning of Chapter 2E) under the Automatic Enrolment Retirement Savings System Act 2024;”,

and

(iv) by the insertion of the following definition:

“ ‘participant’ has the same meaning as it has in Chapter 2E;”,

and

(k) in section 790AA(1)(a), in the definition of “relevant pension arrangement”—

(i) in subparagraph (vii), by the substitution of “that Chapter,” for “that Chapter;”, and

(ii) by the insertion of the following subparagraph after subparagraph (vii):

“(viii) the automatic enrolment retirement savings system established, maintained and controlled by the Authority (within the meaning of Chapter 2E) under the Automatic Enrolment Retirement Savings System Act 2024;”.

(2) Section 85 of the Capital Acquisitions Tax Consolidation Act 2003 is amended by the substitution of the following subsection for subsection (1):

“(1) In this section—

‘Act of 1997’ means the Taxes Consolidation Act 1997;

‘Act of 2024’ means the Automatic Enrolment Retirement Savings System Act 2024;

‘Authority’ has the same meaning as it has in the Act of 2024;

‘balance’ has the same meaning as it has in section 78 of the Act of 2024;

‘participant’ has the same meaning as it has in the Act of 2024;

‘participant account’, in relation to a participant, means the account maintained for the participant by the Authority under section 76 of the Act of 2024;

‘retirement fund’, in relation to an inheritance taken on death of a disponer, means—

- (a) a fund that is—

    - (i) an approved retirement fund or an approved minimum retirement fund, within the meaning of section 784A or 784C of the Act of 1997,

    - (ii) a Personal Retirement Savings Account, within the meaning of section 787A of the Act of 1997, where assets of the Personal Retirement Savings Account are treated under subsection (4) or (4B), as the case may be, of section 787G of that Act as having been made available to an individual,

    - (iii) a vested RAC within the meaning of section 787O(1) of the Act of 1997, or

    - (iv) a PEPP, within the meaning of Chapter 2D of Part 30 of the Act of 1997, where assets of the PEPP are treated under subsection (4) or (6), as the case may be, of section 787AA of that Act as having been made available to an individual,

      being wholly comprised of all or any of the following, that is—

        - (I) property which represents in whole or in part the accrued rights of the disponer, or of a predeceased spouse or civil partner of the disponer, under—

        - (A) an annuity contract or retirement benefits scheme approved by the Commissioners for the purposes of Chapter 1 or 2 of Part 30 of the Act of 1997, or

        - (B) a Personal Retirement Savings Account being a PRSA product approved by the Commissioners for the purposes of Chapter 2A of Part 30 of the Act of 1997,

            - (II) any accumulations of income of such property,

            - (III) property which represents in whole or in part these accumulations, or

            - (IV) a PEPP, within the meaning of Chapter 2D of Part 30 of the Act of 1997, registered for the purposes of that Chapter under Article 7 of Regulation (EU) No. 2019/1238 of the European Parliament and Council of 20 June 2019<sup><a href="/ie/law/IE-2025-act-18/5#fn-1">1</a></sup>,

              or

- (b) the balance in a participant’s account, where the Authority sent a notification to the participant, in accordance with section 82(1)(d) of the Act of 2024, that such balance was eligible for withdrawal.”.

(3) Section 82C(1) of the Stamp Duties Consolidation Act 1999 is amended, in the definition of “pension scheme”—

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

(b) 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;”.

19. Amendment of section 128F of Principal Act (key employee engagement programme)

19. (1) Section 128F of the Principal Act is amended—

(a) in subsection (1)—

(i) in the definition of “excluded activities”, by the substitution of the following paragraph for paragraph (c):

“(c) financing activities,”,

and

(ii) by the substitution of the following definition for the definition of “financial activities”:

“ ‘financing activities’ has the same meaning as in section 489;”,

(b) in subsection (3), by the substitution of “1 January 2029” for “1 January 2026”, and

(2) Paragraphs (b) and (c) of subsection (1) shall come into operation on such day as the Minister for Finance may appoint by order.

20. Amendment of Schedule 13 to Principal Act (accountable persons for purposes of Chapter 1 of Part 18)

20. Schedule 13 to the Principal Act is amended—

(a) by the substitution of the following paragraph for paragraph 69:

“69. Temple Bar Cultural Trust Designated Activity Company.”,

and

(b) by the insertion of the following paragraphs after paragraph 217:

“218. Taighde Éireann.

Judicial Appointments Commission.

Comhlacht Formhaoirsithe Seachtrach Óglaigh na hÉireann.

Gambling Regulatory Authority of Ireland.

oifig an Scrúdaitheora Neamhspleách um Reachtaíocht Slándála.”.

21. Amendment of section 530A of Principal Act (principal to whom relevant contracts tax applies)

21. Section 530A of the Principal Act is amended, in subsection (1), by the substitution of the following paragraph for paragraph (d):

“(d) a local authority, a public utility society (within the meaning of section 2 of the Housing Act 1966), a body referred to in section 45 of the Housing Act 1966 and approved for the purposes of the said section 45 or a body referred to in subsection (1) of section 7 of the Housing (Miscellaneous Provisions) Act 1979 and approved for the purposes of the said section 7.”.

22. Amendment of section 823A of Principal Act (deduction for income earned in certain foreign states)

22. Section 823A of the Principal Act is amended—

(a) in subsection (1)—

(i) by the substitution of the following definition for the definition of “qualifying day”:

“ ‘qualifying day’, in relation to an office or employment of an individual, means a day—

(a) which is one throughout the whole of which the individual is present in a relevant state for the purposes of the performance of the duties of the office or employment,

(b) where such day is substantially devoted to the performance of such duties, and

(c) which shall not be counted more than once as a qualifying day;”,

and

(ii) by the substitution of the following definition for the definition of “relevant state”:

“ ‘relevant state’ means, as regards the years of assessment 2012 to 2025, the Russian Federation, and as regards the years of assessment 2012 to 2030, the Federative Republic of Brazil, the Republic of India, the People’s Republic of China or the Republic of South Africa, and includes—

(a) as regards the years of assessment 2013 to 2030, the Arab Republic of Egypt, the People’s Democratic Republic of Algeria, the Republic of Senegal, the United Republic of Tanzania, the Republic of Kenya, the Federal Republic of Nigeria, the Republic of Ghana and the Democratic Republic of the Congo,

(b) as regards the years of assessment 2015 to 2030, Japan, the Republic of Singapore, the Republic of Korea, the Kingdom of Saudi Arabia, the United Arab Emirates, the State of Qatar, the Kingdom of Bahrain, the Republic of Indonesia, the Socialist Republic of Vietnam, the Kingdom of Thailand, the Republic of Chile, the Sultanate of Oman, the State of Kuwait, the United Mexican States and Malaysia,

(c) as regards the years of assessment 2017 to 2030, the Republic of Colombia and the Islamic Republic of Pakistan, and

(d) as regards the years of assessment 2026 to 2030, the Republic of the Philippines and the Republic of Türkiye;”,

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

“(1A) For the purposes of the definition, in subsection (1), of ‘qualifying day’—

(a) presence in a relevant state shall include the duration of time spent travelling directly from the State to a relevant state, and from a relevant state to the State or to another relevant state,

(b) a day shall be a qualifying day only where the individual’s presence in the relevant state is reasonably required for the purposes of the performance of the duties of the office or employment, and

(c) a day shall not be precluded from being a qualifying day solely on the grounds that the duties of the office or employment could have been performed in the State on that day.”,

“(3) Where for any year of assessment an individual resident in the State makes a claim in that behalf to and satisfies an authorised officer that either—

(a) the number of days in that year which are qualifying days in relation to an office or employment of the individual (together with any days which are qualifying days in relation to any other such office or employment of the individual), or

(b) the number of such days referred to in paragraph (a) in a relevant period in relation to that year and no part of which period is comprised in any other relevant period,

amounts to at least 30 days, there shall be deducted from the income, profits or gains of the individual from all offices or employments assessable under Schedule D or E, as may be appropriate, an amount equal to the specified amount in relation to that office or employment or those offices or employments but that amount, or the aggregate of those amounts where there is more than one such office or employment, shall not exceed €50,000.”,

and

(d) in subsection (6), by the substitution of “2015 to 2030” for “2015 to 2025”.

23. Amendment of section 825C of Principal Act (special assignee relief programme)

23. Section 825C of the Principal Act is amended—

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

“(2AB) In this section, in the case of an individual who arrives in the State in any of the tax years 2026 to 2030, ‘relevant employee’ means an individual—

(a) who, for the whole of the 6 months immediately before his or her arrival in the State, was a full time employee of a relevant employer and exercised the duties of his or her employment for that relevant employer outside the State,

(b) who arrives in the State at the request of his or her relevant employer—

(i) to perform in the State duties of his or her employment for that employer, or

(ii) to take up employment in the State with an associated company and to perform duties in the State for that company,

(c) who performs the duties referred to in paragraph (b) for a minimum period of 12 consecutive months from the date he or she first performs those duties in the State,

(d) who, for the year of arrival in the State, is entitled to receive income, profits or gains from an employment with a relevant employer or an associated company, which, after excluding the amounts referred to at paragraphs (a) to (h) of the definition, in subsection (1), of ‘relevant income’, is not less than the annualised equivalent of €125,000,

(e) to whom a PPS number has been issued,

(f) who was not resident in the State for the 5 tax years immediately preceding the tax year in which he or she first arrives in the State for the purposes of performing the duties referred to in paragraph (b), and

(g) in respect of whom the relevant employer or associated company certifies, in such form as the Revenue Commissioners may require, within 90 days from the employee’s arrival in the State to perform the duties referred to in paragraph (b), that—

(i) the individual complies with the conditions set out in paragraphs (a) to (e), and

(ii) the relevant employer or associated company has complied with Regulation 17(2) of the Income Tax (Employments) Regulations 2018 (S.I. No. 345 of 2018),

but where such certification is made after 90 days but within 180 days from the date of the employee’s arrival in the State, the individual shall be deemed to be a relevant employee for the purposes of this section.”,

(b) in subsection (2B)(b)—

(i) in subparagraph (i)—

(I) by the substitution of “referred to in subsection (2)(a)(ii), (2A)(b), (2AA)(b) or (2AB)(b)” for “referred to in subsection (2)(a)(ii), (2A)(b) or (2AA)(b)”, and

(II) in subclause (B), by the substitution of “set out in subsection (2A)(b), (2AA)(b) or (2AB)(b)” for “set out in subsection (2A)(b) or (2AA)(b)”,

and

(ii) by the substitution of the following subparagraph for subparagraph (ii)—

“(ii) ‘B’ is €75,000 or, in the case of a relevant employee who arrives in the State—

(I) in any of the tax years 2023 to 2025, €100,000, or

(II) in any of the tax years 2026 to 2030, €125,000.”,

(i) in paragraph (a)—

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

“(ii) performs the duties referred to in subsection (2)(a)(ii), (2A)(b), (2AA)(b) or (2AB)(b), and”,

and

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

“(iii) has relevant income from his or her relevant employer or from the associated company, the annualised equivalent of which is—

(I) subject to clauses (II) and (III), not less than €75,000,

(II) in the case of a relevant employee who arrives in the State in any of the tax years 2023 to 2025, not less than €100,000, or

(III) in the case of a relevant employee who arrives in the State in any of the tax years 2026 to 2030, not less than €125,000,”,

and

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

“(c) (i) A relevant employee, other than a relevant employee referred to in subsection (2AB), shall only be entitled to relief under this section for 5 consecutive tax years, commencing with the tax year for which the relevant employee is first entitled to relief under this section.

(ii) A relevant employee referred to in subsection (2AB) shall only be entitled to relief under this section for—

(I) 5 consecutive tax years, commencing with the tax year for which the relevant employee is first entitled to relief under this section, where the certification referred to in paragraph (g) of subsection (2AB) is made within 90 days from the employee’s arrival in the State, or

(II) 4 consecutive tax years, commencing with the tax year after which the relevant employee is first entitled to relief under this section, where the certification referred to in paragraph (g) of subsection (2AB) is made after 90 days but within 180 days from the employee’s arrival in the State.”,

(d) in subsection (4)(b)—

(i) by the substitution of “2030” for “2025”, and

(ii) in subparagraph (i), by the substitution of “set out in subsection (2A)(b), (2AA)(b) or (2AB)(b)” for “set out in subsection (2A)(b) or (2AA)(b)”,

and

(e) in subsection (10), by the substitution of “30 June” for “23 February”.

24. Amendment of section 121 of Principal Act (benefit of use of car)

24. Section 121(4A) of the Principal Act is amended—

(a) in paragraph (a), by the substitution of “column (3), (4), (5), (6), (7) or (8)” for “column (3), (4), (5), (6) or (7)”,

(b) in paragraph (aa)—

(i) in subparagraph (iv), by the substitution of “subject to paragraph (ab), €20,000” for “€20,000”, and

(ii) in subparagraph (v), by the substitution of “subject to paragraph (ab), €10,000” for “€10,000”,

(i) by the substitution of “each of the years of assessment 2023 to 2028 (both years inclusive)” for “the years of assessment 2023, 2024 and 2025”,

(ii) in subparagraph (i)—

(I) by the substitution of “subparagraph (i), (ii), (iii), (iv) or (v)” for “subparagraph (i), (ii) or (iii)”,

(II) in clause (I), by the substitution of “subparagraph (i), (ii), (iii), (iv) or (v)” for “subparagraph (i), (ii) or (iii)”,

(III) by the substitution of the following for clause (II):

“(II) €10,000 for each of the years of assessment 2023 to 2026 (both years inclusive), €5,000 for the year of assessment 2027 and €2,500 for the year of assessment 2028,”,

and

(iii) in subparagraph (ii)—

(I) by the substitution of “A1, A, B, C and D” for “A, B, C and D”, and

(II) by the substitution of “an amount ascertained under clause (II)” for “€10,000”,

(d) in paragraph (b), by the substitution of “column (3), (4), (5), (6), (7) or (8)” for “column (3), (4), (5), (6) or (7)” in both places where it occurs, and

(e) in paragraph (d)—

(i) by the substitution of the following Table for Table A:

“TABLE A

Business Mileage Business Mileage Vehicle Categories Vehicle Categories Vehicle Categories Vehicle Categories Vehicle Categories Vehicle Categories

Lower limit (1) Upper limit (2) A1 (3) A (4) B (5) C (6) D (7) E (8)

Kilometres Kilometres Per cent Per cent Per cent Per cent Per cent Per cent

— 26,000 15 22.5 26.25 30 33.75 37.5

26,001 39,000 12 18 21 24 27 30

39,001 48,000 9 13.5 15.75 18 20.25 22.5

48,001 — 6 9 10.5 12 13.5 15

”,


Business Mileage	Business Mileage	Vehicle Categories	Vehicle Categories	Vehicle Categories	Vehicle Categories	Vehicle Categories	Vehicle Categories
Lower limit (1)	Upper limit (2)	A1 (3)	A (4)	B (5)	C (6)	D (7)	E (8)
Kilometres	Kilometres	Per cent	Per cent	Per cent	Per cent	Per cent	Per cent
—	26,000	15	22.5	26.25	30	33.75	37.5
26,001	39,000	12	18	21	24	27	30
39,001	48,000	9	13.5	15.75	18	20.25	22.5
48,001	—	6	9	10.5	12	13.5	15

and

(ii) by the substitution of the following Table for Table B:

“TABLE B

Vehicle Category (1) CO2 Emissions (CO2 g/km) (2)

A1 0g/km

A More than 0g/km up to and including 59g/km

B More than 59g/km up to and including 99g/km

C More than 99g/km up to and including 139g/km

D More than 139g/km up to and including 179g/km

E More than 179g/km

”.


Vehicle Category (1)	CO2 Emissions (CO2 g/km) (2)
A1	0g/km
A	More than 0g/km up to and including 59g/km
B	More than 59g/km up to and including 99g/km
C	More than 99g/km up to and including 139g/km
D	More than 139g/km up to and including 179g/km
E	More than 179g/km

25. Amendment of section 121A of Principal Act (benefit of use of van)

25. Section 121A(2)(b) of the Principal Act is amended—

(a) in subparagraph (vii)—

(i) in clause (IV), by the substitution of “subject to subparagraph (viii), €20,000” for “€20,000”, and

(ii) in clause (V), by the substitution of “subject to subparagraph (viii), €10,000” for “€10,000”,

and

(b) in subparagraph (viii)—

(i) by the substitution of “each of the years of assessment 2023 to 2028 (both years inclusive)” for “the years of assessment 2023, 2024 and 2025”,

(ii) in clause (I)—

(I) by the substitution of “clause (I), (II), (III), (IV) or (V)” for “clause (I), (II) or (III)”,

(II) in subclause (A), by the substitution of “clause (I), (II), (III), (IV) or (V)” for “clause (I), (II) or (III)”, and

(III) by the substitution of the following subclause for subclause (B):

“(B) €10,000 for each of the years of assessment 2023 to 2026 (both years inclusive), €5,000 for the year of assessment 2027 and €2,500 for the year of assessment 2028,”,

and

(iii) in clause (II), by the substitution of “an amount ascertained under clause (I) (B)” for “€10,000”.

Chapter 4 Income Tax, Corporation Tax and Capital Gains Tax

26. Amendment of section 285A of Principal Act (acceleration of wear and tear allowances for certain energy-efficient equipment)

26. Section 285A of the Principal Act is amended, in subsection (1), in the definition of “relevant period”, by the substitution of “31 December 2030” for “31 December 2025”.

27. Amendment of section 285C of Principal Act (acceleration of wear and tear allowances for gas vehicles and refuelling equipment)

27. Section 285C of the Principal Act is amended, in subsection (1), in the definition of “relevant period”, by the substitution of “31 December 2030” for “31 December 2025”.

28. Amendment of section 285D of Principal Act (acceleration of wear and tear allowances for farm safety equipment)

28. Section 285D of the Principal Act is amended, in subsection (18)—

(a) in paragraph (b), by the substitution of “, Regulation (EU) 2019/1243 of the European Parliament and of the Council of 20 June 2019² and Commission Delegated Regulation (EU) 2023/137 of 10 October 2022³” for “and Regulation (EU) 2019/1243 of the European Parliament and of the Council of 20 June 2019⁴”, and

(b) in paragraph (c), by the substitution of “Commission Delegated Regulation (EU) 2019/1755 of 8 August 2019⁵ and Commission Delegated Regulation (EU) 2023/674 of 26 December 2022⁶” for “and Commission Delegated Regulation (EU) 2019/1755 of 8 August 2019⁷”.

29. Amendment of section 658A of Principal Act (farming: accelerated allowances for capital expenditure on slurry storage)

29. Section 658A of the Principal Act is amended—

(a) in subsection (1), in the definition of “relevant period”, by the substitution of “31 December 2029” for “31 December 2025”, and

(b) in subsection (7)—

(i) in paragraph (b), by the substitution of “, Regulation (EU) 2019/1243 of the European Parliament and of the Council of 20 June 2019⁸ and Commission Delegated Regulation (EU) 2023/137 of 10 October 2022⁹” for “and Regulation (EU) 2019/1243 of the European Parliament and of the Council of 20 June 2019¹⁰”, and

(ii) in paragraph (c), by the substitution of “, Commission Delegated Regulation (EU) 2019/1755 of 8 August 2019¹¹ and Commission Delegated Regulation (EU) 2023/674 of 26 December 2022¹²” for “and Commission Delegated Regulation (EU) 2019/1755 of 8 August 2019¹³”.

30. Living City Initiative

30. The Principal Act is amended—

(a) in section 372AAA(1)—

(i) in the definition of “qualifying period”, by the substitution of “31 December 2030” for “31 December 2027”,

(ii) in the definition of “relevant house”, by the substitution of “1975” for “1915”, and

(iii) by the insertion of the following definitions:

“ ‘Commission Regulation (EU) 2023/2831’ means Commission Regulation (EU) 2023/2831 of 13 December 2023¹⁴ on the application of Articles 107 and 108 of the Treaty on the Functioning of the European Union to de minimis aid;

‘de minimis aid’ means aid granted in compliance with Commission Regulation (EU) 2023/2831;

‘permissible ceiling of aid’ means the maximum amount of de minimis aid of €300,000 that may be granted to a single undertaking over any period of 3 years in accordance with Commission Regulation (EU) 2023/2831;

‘single undertaking’ has the meaning given to it by Article 2(2) of Commission Regulation (EU) 2023/2831;”,

(b) in section 372AAC—

(i) in subsection (1)—

(I) by the deletion of the definition of “property developer”, and

(II) by the substitution of the following definition for the definition of “qualifying expenditure”:

“ ‘qualifying expenditure’, means, notwithstanding section 279, capital expenditure incurred in the qualifying period on the conversion or the refurbishment of a qualifying premises after deducting from that amount of expenditure any sum in respect of or by reference to—

(a) that expenditure,

(b) the qualifying premises, or

(c) the conversion work, or as the case may be, the refurbishment work in respect of which that expenditure was incurred,

which the person has received or is entitled to receive, directly or indirectly, from the State, any board established by statute or any public or local authority, and for the purposes of giving relief under this section, any reference to expenditure being incurred shall include a reference to expenditure deemed under any provision of Part 9 to be incurred;”,

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

(iii) by the substitution of the following subsection for subsection (4):

“(4)

(a) In relation to qualifying expenditure incurred before 1 January 2026 in the qualifying period on a qualifying premises, section 272 shall apply as if—

(i) in subsection (3)(a)(ii) of that section the reference to 4 per cent were a reference to 15 per cent, and

(ii) in subsection (4)(a) of that section the following were substituted for subparagraph (ii):

‘(ii) where capital expenditure on the conversion or refurbishment of the building or structure is incurred, 7 years beginning with the time when the building or structure was first used subsequent to the incurring of that expenditure.’.

(b) In relation to qualifying expenditure incurred on or after 1 January 2026 in the qualifying period on a qualifying premises, section 272 shall apply as if—

(i) in subsection (3)(a)(ii) of that section the reference to 4 per cent were a reference to 50 per cent, and

(ii) in subsection (4)(a) of that section the following were substituted for subparagraph (ii):

‘(ii) where capital expenditure on the conversion or refurbishment of the building or structure is incurred, 10 years beginning with the time when the building or structure was first used subsequent to the incurring of that expenditure.’.”,

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

“(5) Notwithstanding section 274(1), no balancing allowance or balancing charge shall be made in relation to a qualifying premises by reason of any event referred to in that section which occurs more than—

(a) 7 years after the qualifying premises was first used subsequent to the incurring of the qualifying expenditure on the conversion or refurbishment of the qualifying premises where that qualifying expenditure was incurred before 1 January 2026, or

(b) 10 years after the qualifying premises was first used subsequent to the incurring of the qualifying expenditure on the conversion or refurbishment of the qualifying premises where that qualifying expenditure was incurred on or after 1 January 2026.”,

(v) by the deletion of subsections (8), (8A) and (10), and

(vi) by the insertion of the following subsection after subsection (10):

“(11) A claim for relief in accordance with this section may only be made by a person insofar as the aggregate of the claim, when taken together with other de minimis aid received, does not exceed the permissible ceiling of aid to the single undertaking of which the person is a part.”,

(i) in subsection (1)—

(I) by the deletion of the definition of “property developer”,

(II) by the substitution of the following definition for the definition of “eligible expenditure”:

“ ‘eligible expenditure’, means, notwithstanding section 279, capital expenditure incurred in the relevant qualifying period on the conversion or the refurbishment of a special qualifying premises after deducting from that amount of expenditure any sum in respect of or by reference to—

(a) that expenditure,

(b) the special qualifying premises, or

(c) the conversion work, or as the case may be, the refurbishment work in respect of which that expenditure was incurred,

which the person has received or is entitled to receive, directly or indirectly, from the State, any board established by statute or any public or local authority, and for the purposes of giving relief under this section, any reference to expenditure being incurred shall include a reference to expenditure deemed under any provision of Part 9 to be incurred;”,

and

(III) in the definition of “relevant qualifying period”, by the substitution of “31 December 2030” for “31 December 2027”,

(ii) by the deletion of subsection (2),

(iii) by the substitution of the following subsection for subsection (4):

“(4)

(a) In relation to eligible expenditure incurred before 1 January 2026 in the relevant qualifying period on a special qualifying premises, section 272 shall apply as if—

(i) in subsection (3)(a)(ii) of that section the reference to 4 per cent were a reference to 15 per cent, and

(ii) in subsection (4)(a) of that section the following were substituted for subparagraph (ii):

‘(ii) where capital expenditure on the conversion or refurbishment of the building or structure is incurred, 7 years beginning with the time when the building or structure was first used subsequent to the incurring of that expenditure.’.

(b) In relation to eligible expenditure incurred on or after 1 January 2026 in the relevant qualifying period on a special qualifying premises, section 272 shall apply as if—

(i) in subsection (3)(a)(ii) of that section the reference to 4 per cent were a reference to 50 per cent, and

(ii) in subsection (4)(a) of that section the following were substituted for subparagraph (ii):

‘(ii) where capital expenditure on the conversion or refurbishment of the building or structure is incurred, 10 years beginning with the time when the building or structure was first used subsequent to the incurring of that expenditure.’.”,

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

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FINANCE ACT 2025

PART 1 Universal Social Charge, Income Tax, Corporation Tax and Capital Gains Tax

Chapter 1 Interpretation

1. Definition (Part 1)

Chapter 2 Universal Social Charge

2. Amendment of section 531AN of Principal Act (rate of charge)

“PART 1

Chapter 3 Income Tax

3. Amendment of section 473B of Principal Act (rent tax credit)

4. Amendment of section 473C of Principal Act (mortgage interest tax relief)

5. Amendment of section 477C of Principal Act (Help to Buy)

6. Amendment of section 204B of Principal Act (exemption in respect of compensation for certain living donors)

7. Amendment of section 208B of Principal Act (charities - miscellaneous)

8. Amendment of section 235 of Principal Act (bodies established for promotion of athletic or amateur games or sports)

9. Amendment of section 847A of Principal Act (donations to certain sports bodies)

10. Amendment of section 531AM of Principal Act (charge to universal social charge)

11. Amendment of section 847AA of Principal Act (deduction for donations to National Governing Bodies)

12. Amendment of section 216D of Principal Act (certain profits of micro-generation of electricity)

13. Amendment of section 216F of Principal Act (exemption of certain profits arising from production, maintenance and repair of certain musical instruments)

14. Annual returns by qualifying fund managers

15. Repeal of section 14 of Finance Act 2024

16. Automatic enrolment retirement savings system

“CHAPTER 2E

17. Repeal of section 15 of Finance Act 2024

18. Automatic enrolment retirement savings system (amendments consequential on insertion of Chapter 2E in Part 30)

19. Amendment of section 128F of Principal Act (key employee engagement programme)

20. Amendment of Schedule 13 to Principal Act (accountable persons for purposes of Chapter 1 of Part 18)

21. Amendment of section 530A of Principal Act (principal to whom relevant contracts tax applies)

22. Amendment of section 823A of Principal Act (deduction for income earned in certain foreign states)

23. Amendment of section 825C of Principal Act (special assignee relief programme)

24. Amendment of section 121 of Principal Act (benefit of use of car)

25. Amendment of section 121A of Principal Act (benefit of use of van)

Chapter 4 Income Tax, Corporation Tax and Capital Gains Tax

26. Amendment of section 285A of Principal Act (acceleration of wear and tear allowances for certain energy-efficient equipment)

27. Amendment of section 285C of Principal Act (acceleration of wear and tear allowances for gas vehicles and refuelling equipment)

28. Amendment of section 285D of Principal Act (acceleration of wear and tear allowances for farm safety equipment)

29. Amendment of section 658A of Principal Act (farming: accelerated allowances for capital expenditure on slurry storage)

30. Living City Initiative

1. **Definition (Part 1)**