LegalizeFinance Act 2025
PART 1 Universal Social Charge, Income Tax, Corporation Tax and Capital Gains Tax
Chapter 1 Interpretation
1. Definition (Part 1)
1. In this Part, “Principal Act” means the Taxes Consolidation Act 1997.
Chapter 2 Universal Social Charge
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
(c) by the substitution of the following for Part 1 of the Table to that section:
“PART 1
| Part of aggregate income (1) | Rate of universal social charge (2) |
|---|---|
| The first €12,012 | 0.5 per cent |
| The next €16,688 | 2 per cent |
| The next €41,344 | 3 per cent |
| The remainder | 8 per cent |
”.
(2) Subsection (1) applies for the year of assessment 2026 and each subsequent year of assessment.
Chapter 3 Income Tax
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)”,
(c) by the insertion of the following subsections after subsection (4A):
“(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.”,
(c) in subsection (9)—
(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. Amendment of section 531AM of Principal Act (charge to universal social charge)
10. Section 531AM of the Principal Act is amended, in paragraph (b)(viii)(II) of the Table to that section—
(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”,
⋯
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