Finance Act 2025

(i) treated as an overpayment of tax, for the purposes of section 960H, or

(ii) paid to the company by the Revenue Commissioners.

(b) Subject to paragraph (c), the company shall make the specification referred to in paragraph (a)—

(i) in respect of the first instalment, in the return referred to in subsection (8),

(ii) in respect of the second instalment, if any, in the return that the company is required to file under Part 41A in respect of the accounting period (in this paragraph referred to as ‘the first mentioned accounting period’) immediately succeeding the accounting period in respect of which the claim was made, and

(iii) in respect of the third instalment, if any, in the return that the company is required to file under Part 41A in respect of the accounting period immediately succeeding the first-mentioned accounting period.

(c) Where, in relation to an accounting period, a company makes a claim in respect of the credit in accordance with subsection (8) (in this paragraph referred to as ‘the first-mentioned claim’), and a second or third instalment is payable in accordance with subsection (10) in respect of a claim for the credit made in an earlier accounting period, the company may make the specification referred to in paragraph (a) in respect of the second or third instalment, or both, as the case may be, on the making of the first mentioned claim.”,

(v) in subsection (9)(a), by the substitution of “subsection (6)(a)(i) or paid to the company under subsection (6)(a)(ii)” for “subsection (6)(a) or paid to the company under subsection (6)(b)”,

(vi) in subsection (10)(c), by the substitution of the following subparagraph for subparagraph (i):

“(i) where the first-mentioned accounting period is for a period of 12 months and the accounting period (in this subparagraph referred to as ‘the second-mentioned accounting period’) immediately succeeding the first-mentioned accounting period is for a period of 12 months, on the filing of the return that the company is required to file under Part 41A for the second mentioned accounting period, or”,

(vii) in subsection (12), by the substitution of “subsection (6)(a)(i)” for “subsection (6)(a)”, and

(viii) in subsection (14), by the substitution of “subsection (6)(a)(i) or to be paid under subsection (6)(a)(ii)” for “subsection (6)(a) or to be paid under subsection (6)(b)”.

(2) (a) Paragraph (a), subparagraphs (i) and (iii) of paragraph (c) and subparagraph (i) of paragraph (d) of subsection (1) shall apply in respect of any accounting period the specified return date (within the meaning of Part 41A) of which is on or after 23 September 2027.

(b) Paragraph (b) of subsection (1) shall apply on and from the date of the passing of this Act.

(c) Subparagraphs (ii), (iv), (v), (vi), (viii) and (ix) of paragraph (c) and subparagraphs (ii), (iii), (iv), (v), (vii) and (viii) of paragraph (d) of subsection (1) shall apply in respect of accounting periods ending on or after 31 December 2025.

(d) Paragraph (c)(vii) of subsection (1) shall apply in respect of instalments payable in accordance with section 766C on and from the date of the passing of this Act.

(e) Paragraph (d)(vi) of subsection (1) shall apply in respect of instalments payable in accordance with section 766D on and from the date of the passing of this Act.

36. Taxation of certain foreign body corporates

36. Part 43 of the Principal Act is amended by the insertion of the following section after section 1009:

“1009A. Notwithstanding any provision of the Tax Acts or the Capital Gains Tax Acts, as the case may be, a body corporate and each of its members shall be chargeable to tax or capital gains tax, as the case may be, on their respective income, profits or gains on the basis that the body corporate is a partnership and each of its members are partners in a partnership where—

(a) the body corporate is incorporated, or formed, under the laws of a jurisdiction other than the State, and

(b) having regard to the characteristics of that body corporate and the rights and obligations of each of its members, the body corporate is substantially similar to a partnership formed under the law of the State.”.

37. Life assurance policies and investment funds

37. (1) The Principal Act is amended—

(a) in section 730F(1)(a)(ii), by the substitution of “38 per cent” for “41 per cent”,

(b) in section 730J(a)(i)(II), by the substitution of “38 per cent” for “41 per cent”,

(c) in section 730K(1)(a)(ii), by the substitution of “38 per cent” for “41 per cent”,

(d) in section 739D(5A), in the formula in paragraph (b), by the substitution of “(G x 38)” for “(G x 41)”,

(e) in section 739E(1)—

(i) in paragraph (a)(ii), by the substitution of “38 per cent” for “41 per cent”, and

(ii) in paragraph (b)(ii), by the substitution of “38 per cent” for “41 per cent”,

(f) in section 747D(a)(i)(II), by the substitution of “38 per cent” for “41 per cent”, and

(g) in section 747E(1)(b)(ii), by the substitution of “38 per cent” for “41 per cent”.

(2) (a) Subsection (1)(a) applies and has effect as respects the happening of a chargeable event in relation to a life policy (within the meaning of Chapter 5 of Part 26 of the Principal Act) on or after 1 January 2026.

(b) Subsection (1)(b) applies and has effect as respects the receipt by a person of a payment in respect of a foreign life policy (within the meaning of Chapter 6 of Part 26 of the Principal Act) on or after 1 January 2026.

(c) Subsection (1)(c) applies and has effect as respects the disposal in whole or in part of a foreign life policy (within the meaning of Chapter 6 of Part 26 of the Principal Act) on or after 1 January 2026.

(d) Subsection (1)(d) and (e) apply and have effect as respects the happening of a chargeable event in relation to an investment undertaking (within the meaning of section 739B(1) of the Principal Act) on or after 1 January 2026.

(e) Subsection (1)(f) applies and has effect as respects the receipt by a person of a payment in respect of a material interest in an offshore fund (within the meaning of Chapter 4 of Part 27 of the Principal Act) on or after 1 January 2026.

(f) Subsection (1)(g) applies and has effect as respects the disposal in whole or in part by a person of a material interest in an offshore fund (within the meaning of Chapter 4 of Part 27 of the Principal Act) on or after 1 January 2026.

38. Amendment of section 731 of Principal Act (chargeable gains accruing to unit trusts)

38. (1) Section 731 of the Principal Act is amended, in subsection (5)(a)(i), by the substitution of “(otherwise than by reason of residence, by virtue of section 739(3) or by virtue of section 739C(1))” for “(otherwise than by reason of residence or by virtue of section 739(3))”.

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

39. Exemption from dividend withholding tax for certain investment limited partnerships

39. (1) Part 6 of the Principal Act is amended—

(a) in section 172A(1)(a), by the insertion of the following definitions:

“ ‘equivalent partnership’ means a partnership which would be an investment limited partnership but for the fact that it is authorised by an EEA state other than the State and is subject to such supervisory and regulatory arrangements in the EEA state by which it is authorised at least equivalent to those applied to an investment limited partnership;

‘investment limited partnership’ means a partnership authorised in accordance with the Investment Limited Partnerships Act 1994;”,

and

(b) in section 172C—

(i) in subsection (2), by the insertion of the following paragraph after paragraph (db):

“(dc) subject to subsection (4), an investment limited partnership or equivalent partnership, as the case may be, where—

(i) the partners of the investment limited partnership or equivalent partnership are beneficially entitled to not less than 51 per cent of the ordinary share capital of the company making the relevant distribution,

(ii) the ordinary share capital of the company making the relevant distribution is an asset of that investment limited partnership or equivalent partnership, and

(iii) that investment limited partnership or equivalent partnership has made a declaration, to the company making the relevant distribution, in relation to the relevant distribution in accordance with paragraph 14 of Schedule 2A,”,

(ii) in subsection (3)—

(I) in paragraph (d), by the deletion of “and”,

(II) in paragraph (e), by the substitution of “PEPP assets, and” for “PEPP assets,”, and

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

“(f) an investment limited partnership or equivalent partnership, as the case may be, which receives a relevant distribution,”,

and

(iii) in subsection (4), by the substitution of “paragraph (bd) or (dc) of subsection (2)” for “subsection (2)(bd)”.

(2) Section 739J of the Principal Act is amended by the insertion of the following subsection after subsection (3A):

“(3B) A statement made under subsection (3) shall be treated as if it satisfies the requirements in respect of the making of a return under section 880, 959I or 959M, as the case may be.”.

(3) Schedule 2A of the Principal Act is amended by the insertion of the following paragraph after paragraph 13:

“Declaration to be made by investment limited partnership or equivalent partnership under section 172C(2)(dc)

(a) is made by the person (in this paragraph referred to as ‘the declarer’) beneficially entitled to the relevant distributions in respect of which the declaration is made,

(b) is signed by the declarer,

(c) is made in such form as may be prescribed or authorised by the Revenue Commissioners,

(d) declares that, at the time when the declaration is made, the person beneficially entitled to the relevant distributions is an investment limited partnership or equivalent partnership,

(e) contains the name and tax reference number of the investment limited partnership or equivalent partnership,

(f) contains an undertaking by the declarer that, if the person mentioned in subparagraph (d) ceases to be an excluded person, the declarer will, by notice in writing, advise the company resident in the State in relation to the relevant distributions accordingly, and

(g) contains such other information as the Revenue Commissioners may reasonably require for the purposes of Chapter 8A of Part 6.”.

(4) (a) Subsection (1) and (3) shall apply in respect of a relevant distribution (within the meaning of section 172A of the Principal Act) made on or after 1 January 2026.

(b) Subsection (2) shall apply for the year of assessment 2026 and each subsequent year.

40. Amendment to section 835AVB of Principal Act (collective investment scheme)

40. (1) Section 835AVB of the Principal Act is amended—

(a) in subsection (1)—

(i) by the insertion of the following definitions:

“ ‘EEA Agreement’ means the Agreement on the European Economic Area signed at Oporto on 2 May 1992, as adjusted by all subsequent amendments to that Agreement;

‘EEA state’ means a state which is a contracting party to the EEA Agreement;

‘foreign tax’, in relation to a relevant territory, means a tax which—

(a) corresponds to corporation tax in the State,

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

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

‘investment limited partnership’ means a partnership authorised in accordance with the Investment Limited Partnerships Act 1994;

‘listed territory’ has the same meaning as it has in section 835YA;

‘relevant company’, in relation to an investment limited partnership, means a company—

(a) which is a direct or indirect asset of the investment limited partnership,

(b) in which the partners of the investment limited partnership are beneficially entitled, directly or indirectly, to not less than 95 per cent of its ordinary share capital,

(c) whose business consists of the holding, directly or indirectly, of a diversified portfolio of assets, and

(d) which is—

(i) resident in the State, or

(ii) by virtue of the law of a relevant territory, is—

(I) resident for the purposes of foreign tax in the relevant territory, and

(II) not generally exempt from foreign tax;

‘relevant territory’ means—

(a) an EEA state, other than the State,

(b) not being such an EEA state, a territory with the government of which arrangements having the force of law by virtue of section 826(1) have been made, or

(c) not being a territory referred to in paragraph (a) or (b), a territory with the government of which arrangements have been made which on completion of the procedures set out in section 826(1) will have the force of law,

but does not include a listed territory;”,

and

(ii) in paragraph (b) of the definition of “relevant investment undertaking”, by the deletion of “, within the meaning of section 739J”,

(b) in subsection (4)(a), by the substitution of “20 per cent” for “10 per cent”, and

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

“(4A) In the case of an investment limited partnership, for the purposes of subsection (4)(a)—

(a) a relevant company shall not be considered to be an issuer of securities to the investment limited partnership, and

(b) an investment limited partnership shall be deemed to hold directly any securities held by a relevant company.”.

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

41. Amendments relating to group payments

41. (1) The Principal Act is amended—

(a) in section 410—

(i) in subsection (1)(a)—

(I) by the substitution of the following definition for the definition of “tax”:

“ ‘tax’, in relation to a relevant territory other than the State, means any tax imposed in the relevant territory which corresponds to corporation tax in the State;”,

and

(II) by the insertion of the following definition:

“ ‘relevant territory’ means—

(i) a relevant Member State,

(ii) not being a territory referred to in subparagraph (i), a territory with the government of which arrangements having the force of law by virtue of section 826(1) have been made, or

(iii) not being a territory referred to in subparagraph (i) or (ii), a territory with the government of which arrangements have been made which on completion of the procedures set out in section 826(1) will have the force of law;”,

(ii) in subsection (1)(b)—

(I) in subparagraph (i), by the substitution of “relevant territory” for “relevant Member State”, and

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

“(ii) references to—

(I) a company resident in a relevant Member State shall be construed as references to a company which, by virtue of the law of a relevant Member State, is resident for the purposes of tax in such a relevant Member State, and

(II) a company resident in a relevant territory shall be construed as references to a company which, by virtue of the law of a relevant territory, is resident for the purposes of tax in such a relevant territory.”,

(iii) in subsection (3)(a), by the substitution of “relevant territory” for “relevant Member State”, and

(iv) in subsection (4)(a)(i), by the substitution of “relevant territory” for “relevant Member State”,

and

(b) in section 243(5)(c), by the substitution of “section 242A, 267I or 410(4)” for “section 242A or 267I”.

(2) Subsection (1) shall apply to payments to which section 410 of the Principal Act applies made on or after the date of the passing of this Act.

Chapter 5 Corporation Tax

42. Enhanced deduction for eligible construction expenditure

42. The Principal Act is amended by the insertion of the following section after section 81D:

“81E. (1) In this section—

‘apartment’ means a separate and self-contained dwelling in a qualifying apartment block—

(a) that has sleeping facilities, bathroom facilities and cooking facilities within it for the exclusive use of the occupant of the dwelling concerned, and

(b) other than where the dwelling is situated on the ground floor of a multi-storey building, access to the dwelling is grouped or in common with other separate and self-contained dwellings;

‘certificate of compliance on completion’, ‘commencement notice’, ‘local authority’, ‘planning permission’ and ‘planning permission period’ have the same meaning, respectively, as they have in section 653A(1);

‘completed development’ means a qualifying apartment block, in respect of which—

(a) planning permission has been granted which includes permission for not fewer than 10 new apartments in the qualifying apartment block,

(b) a relevant commencement notice is lodged with the relevant local authority on or after 8 October 2025 but not later than 31 December 2030, and

(c) on or before the expiry of the planning permission period relating to it—

(i) all works required to ensure that all apartments in the qualifying apartment block are suitable for occupation as a dwelling have been completed, and

(ii) a relevant certificate of compliance on completion is lodged with the relevant local authority;

‘construction operations’ and ‘excepted trade’ have the same meaning, respectively, as they have in section 21A;

‘eligible expenditure’, in relation to a completed development, means, subject to subsection (8), expenditure incurred by a relevant person in connection with construction operations carried out in respect of the completed development, being expenditure which is incurred up to the relevant date, excluding—

(a) any capital expenditure so incurred, and

(b) ineligible expenditure;

‘enhanced deduction’ has the meaning given to it by subsection (4);

‘ineligible expenditure’, in relation to a completed development, means any expenditure incurred by a relevant person in respect of the completed development in respect of any or all of the following:

(a) financing costs;

(b) insurance costs;

(c) professional and legal fees;

(d) sales and marketing costs;

(e) taxes, duties, levies or charges under the care and management of the Revenue Commissioners;

(f) the acquisition of, or rights in or over, any land;

(g) levies, fees, charges or contributions imposed by, or under, any enactment in respect of the completed development concerned, however described in the relevant enactment, including any—

(i) development contributions,

(ii) utility connection charges,

(iii) environmental levies,

(iv) planning application fees,

(v) building control fees, or

(vi) building energy rating fees;

‘land’ includes any interest in land;

‘material change’ shall be construed in accordance with subsection (2);

‘property developer’ means a company carrying on a relevant property development trade;

‘qualifying apartment block’ means a building that—

(a) is a multi-storey building,

(b) is principally comprised of not fewer than 10 apartments, and

(c) is—

(i) a newly erected building, or

(ii) not being a building referred to in subparagraph (i), a building that meets the requirements of paragraphs (a) and (b) as a result of a material change,

and includes an area of land for occupation and enjoyment by its occupants with the building as its gardens or grounds;

‘qualifying refurbishment’ means any work of construction, reconstruction, restoration, repair or renewal, including the provision or improvement of water, sewerage or heating facilities, carried out on a building or structure, or part of a building or structure;

‘qualifying trade’, in relation to a relevant contractor, means a trade carried out by the relevant contractor, which—

(a) is not an excepted trade, and

(b) consists wholly or mainly of the construction or refurbishment of buildings or structures;

‘relevant accounting period’ means the accounting period in which the relevant certificate of compliance on completion in respect of a completed development is lodged with the relevant local authority;

‘relevant beneficial owner’ means a beneficial owner of a completed development that is not a relevant person in respect of that completed development;

‘relevant certificate of compliance on completion’ means a certificate of compliance on completion lodged with the relevant local authority or, where there is more than one such certificate of compliance on completion, the last such certificate of compliance on completion so lodged, in respect of a completed development;

‘relevant commencement notice’ means a commencement notice lodged with the relevant local authority or, where there is more than one such commencement notice, the first such commencement notice so lodged, in respect of a completed development;

‘relevant contractor’, in relation to a completed development, means a company that develops the completed development pursuant to a contract entered into with the beneficial owner, or where there is more than one beneficial owner, the beneficial owners, of that completed development;

‘relevant date’, in relation to a completed development, means the date on which the relevant certificate of compliance on completion is lodged with the relevant local authority in respect of that completed development;

‘relevant declaration’ means a declaration that is made under and in accordance with subsection (3);

‘relevant local authority’, in relation to a completed development, means the local authority in whose functional area the completed development is situated;

‘relevant person’ means—

(a) a property developer that—

(i) in the course of a relevant property development trade, develops a completed development, and

(ii) on the relevant date is a beneficial owner of the completed development,

or

(b) a relevant contractor—

(i) that, in the course of a qualifying trade, develops a completed development, and

(ii) to which a relevant declaration has been made by a relevant beneficial owner, or where there is more than one relevant beneficial owner, a relevant declaration has been made by each relevant beneficial owner, in respect of that completed development;

‘relevant property development trade’, in relation to a property developer, means a trade carried out by the property developer, which—

(a) is not an excepted trade, and

(b) consists wholly or mainly of the construction or refurbishment of buildings or structures with a view to their sale.

(2) For the purposes of this section, there is a material change where, following a qualifying refurbishment, a building or part of a building, or a structure or part of a structure—

(a) although not originally constructed for occupation as a dwelling, or

(b) although originally constructed for occupation as a dwelling, was not suitable for use as a dwelling or has been appropriated to other purposes,

becomes suitable for use as a dwelling.

(3) (a) Where, on the relevant date, a completed development is beneficially owned by a relevant beneficial owner, then—

(i) the relevant beneficial owner, or

(ii) where there is more than one relevant beneficial owner, each relevant beneficial owner,

may make a declaration in accordance with paragraph (c) to a relevant contractor for the purposes of the relevant contractor making a claim for an enhanced deduction under this section.

(b) A relevant declaration shall not be made to more than one relevant contractor in respect of a completed development and, where a relevant declaration is made to more than one relevant contractor in respect of the same completed development, it shall be deemed that no relevant declaration has been made to any relevant contractor in respect of that completed development.

(c) A relevant declaration shall be a declaration in writing to a relevant contractor which—

(i) is made by a relevant beneficial owner of a completed development (in this paragraph referred to as ‘the declarer’) for the purposes of the relevant contractor making a claim for an enhanced deduction under this section,

(ii) is signed by the declarer,

(iii) is made in such form as may be prescribed or authorised by the Revenue Commissioners,

(iv) declares—

(I) that on the relevant date the declarer is a relevant beneficial owner of the completed development and the percentage of the completed development of which the declarer is a relevant beneficial owner on the relevant date,

(II) that the relevant contractor developed the completed development pursuant to a contract entered into by the declarer and the relevant contractor,

(III) that the declarer is not a relevant person,

and

(v) contains—

(I) the name, address and tax reference number of the declarer and relevant contractor,

(II) the address of the completed development and the number of apartments in the completed development, and

(III) such other information as the Revenue Commissioners may reasonably require for the purposes of this section.

(d) Where, in respect of a completed development—

(i) a relevant declaration is made by the relevant beneficial owner, or

(ii) where there is more than one relevant beneficial owner, a relevant declaration is made by each relevant beneficial owner,

to a relevant contractor, then, for the purposes of this section, the relevant contractor shall be deemed to be the beneficial owner, on the relevant date, of the percentage of the completed development beneficially owned on the relevant date by each relevant beneficial owner, who makes the relevant declaration.

(e) A relevant contractor to which a relevant declaration has been made shall keep and retain the relevant declaration for a period of 6 years from the end of the accounting period in which a return has been delivered making a claim under this section in respect of the completed development to which the relevant declaration relates.

(4) Where—

(a) a relevant person has incurred eligible expenditure in respect of a completed development, and

(b) the relevant person is, in the computation of the amount of the profits or gains of a relevant property development trade or a qualifying trade, as the case may be, to be charged to corporation tax under Case I of Schedule D for an accounting period, entitled to any deduction on account of eligible expenditure in respect of the completed development,

then, the relevant person shall, on the making of a claim, be entitled, in the computation of the amount of the profits or gains of that trade for the relevant accounting period, to a further deduction (in this section referred to as an ‘enhanced deduction’) equal to the amount determined under subsection (5).

(5) Subject to subsections (6) and (7), the amount of the enhanced deduction in respect of a completed development shall be equal to the amount determined by the formula—

A x 25%

where—

A is the amount of eligible expenditure incurred by the relevant person in respect of the completed development in respect of which the relevant person is entitled to a deduction in the computation of the amount of the profits or gains of a relevant property development trade or a qualifying trade, as the case may be, to be charged to corporation tax under Case I of Schedule D for an accounting period.

(6) The amount of the enhanced deduction in respect of a completed development shall not exceed the amount determined by the formula—

B x C x D

where—

B is the number of apartments in the completed development,

C is €50,000, and

D is the percentage of the completed development that is beneficially owned by the relevant person, or in the case of a relevant person who is a relevant contractor is deemed, by virtue of subsection (3)(d), to be beneficially owned by the relevant person, on the relevant date.

(7) Any amount of eligible expenditure incurred by a relevant person in respect of a completed development which—

(a) has been or is to be met, directly or indirectly, by grant assistance or any other assistance which is granted by or through the State, any board established by statute, any public or local authority or any other agency of the State,

(b) exceeds the amount which would be payable between independent persons acting at arm’s length in a transaction similar to that in respect of which the expenditure was incurred, or

(c) is incurred as part of a scheme or arrangement, where it is reasonable to consider that the main purpose, or one of the main purposes, is the avoidance of, or reduction in, liability to tax,

shall, in calculating the amount of the enhanced deduction in respect of a completed development, be excluded from the amount represented by ‘A’ in the formula in subsection (5).

(8) Where expenditure is incurred by a relevant person in connection with construction operations in respect of both a completed development and a development that is not a completed development, such expenditure shall be apportioned by the relevant person on a just and reasonable basis.

(9) (a) A claim under this section shall be made by a relevant person within 12 months from the end of the relevant accounting period to which the claim relates and shall be made in the return filed under Part 41A, in respect of that accounting period.

(b) The relevant person shall, when making a claim in accordance with paragraph (a), provide details of—

(i) the eligible expenditure incurred in relation to the completed development and in respect of which the relevant person is claiming an enhanced deduction,

(ii) the number of apartments in the completed development, and

(iii) such other information as the Revenue Commissioners may reasonably require for the purposes of this section.

(10) (a) Where, in computing for tax purposes the profits of a relevant property development trade or a qualifying trade, as the case may be, an enhanced deduction has been claimed by a relevant person and, in computing that deduction, a debt incurred by the relevant person was included in the amount of eligible expenditure, then, if the whole or any part of that debt is thereafter released, an amount equal to the portion of the enhanced deduction which was determined based on the amount released (in this subsection referred to as the ‘disallowed deduction’) shall be treated as a receipt of the relevant property development trade or a qualifying trade, as the case may be, arising in the period in which the release is effected.

(b) Where paragraph (a) applies, and the trade concerned has been permanently discontinued at or after the end of the period for which the enhanced deduction was claimed and before the release was effected, or is treated for tax purposes as if it had been so discontinued, section 91 shall apply as if the disallowed deduction were a sum received after the discontinuance.”.

43. Amendment of section 291A of Principal Act (intangible assets)

43. (1) Section 291A of the Principal Act is amended—

(a) in subsection (6)—

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

“(i) any allowances to be made to a company under section 284 as applied by this section, and any balancing allowances (within the meaning of section 288) to be made to a company in respect of a specified intangible asset or specified intangible assets, and”,

and

(ii) in paragraph (b)—

(I) in subparagraph (i), by the substitution of “in this subparagraph and subparagraph (ia)” for “in this subparagraph”, and

(II) by the insertion of the following subparagraph after subparagraph (i):

“(ia) Notwithstanding that the excess amount remains unallowed for an accounting period and shall be carried forward and treated as an allowance within the meaning of paragraph (a)(i) for the succeeding accounting period in accordance with subparagraph (i), for all other purposes of this Part the excess amount shall be treated as an allowance that has been made in the first accounting period for which it remains unallowed.”,

(b) in subsection (8)(a), by the deletion of “under section 284 as applied by this section”, and

(c) in subsection (9)—

(i) in paragraph (a), by the substitution of “Subject to paragraphs (b) and (c), this section shall not apply” for “This section shall not apply”,

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

“(b) Where, in relation to an acquisition referred to in paragraph (a)—

(i) the transferor and transferee make a joint election under section 615(4) or 617(4), and

(ii) the acquisition does not occur on a transfer to which section 400(6) applies,

the transferee shall be entitled to claim an allowance under section 284 as applied by this section in respect of capital expenditure incurred by it on acquiring the specified intangible asset from the transferor.”,

and

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

“(c) Where an acquisition referred to in paragraph (a) occurs on a transfer to which section 400(6) applies, the transferee shall be entitled to claim allowances under section 284 as applied by this section in respect of the specified intangible asset in accordance with section 400(6).”.

(2) (a) Paragraph (a)(i) of subsection (1) applies as respects any event referred to in section 288(1) of the Principal Act which occurs on or after 8 October 2025.

(b) Paragraphs (a)(ii), (b) and (c) of subsection (1) shall have effect for accounting periods commencing on or after 1 January 2026.

44. Amendment of section 400 of Principal Act (company reconstructions without change of ownership)

44. (1) Section 400 of the Principal Act is amended—

(a) in subsection (6), by the insertion of “in respect of assets which have transferred from the predecessor to the successor on the transfer of the trade,” after “sections 307 and 308; but,”, and

(b) by the insertion of the following subsection after subsection (7A):

“(7B) (a) Where the trade consists of the carrying on of relevant activities (within the meaning of section 291A(5)(a))—

(i) the predecessor shall not be entitled to any relief under section 291A(6)(b)(i) in respect of an excess amount (within the meaning of section 291A(6)(b)(i)), or portion thereof, as the case may be, which relates to a specified intangible asset which transferred from the predecessor to the successor on the transfer of the trade (in this subsection referred to as ‘the transferable excess amount’), and the successor shall be entitled to relief under section 291A(6)(b)(i) in respect of the transferable excess amount, for which the predecessor would have been entitled to claim relief if the predecessor had continued to carry on the trade, and

(ii) the predecessor shall not be entitled to any relief under section 291A(6)(b)(ii) in respect of excess interest (within the meaning of section 291A(6)(b)(ii)), or portion thereof, as the case may be, which was incurred in connection with the provision of a specified intangible asset which transferred from the predecessor to the successor on the transfer of the trade (in this subsection referred to as ‘the transferable excess interest’), and the successor shall be entitled to relief under section 291A(6)(b)(ii) in respect of the transferable excess interest, for which the predecessor would have been entitled to claim relief if the predecessor had continued to carry on the trade.

(b) (i) For the purposes of subparagraph (i) of paragraph (a), where an excess amount referred to in that subparagraph relates to both—

(I) a specified intangible asset which transferred from the predecessor to the successor on the transfer of the trade, and

(II) a specified intangible asset which did not so transfer,

when determining the transferable excess amount, the excess amount shall be apportioned on a just and reasonable basis.

(ii) For the purposes of subparagraph (ii) of paragraph (a), where excess interest referred to in that subparagraph was incurred in connection with both—

(I) the provision of a specified intangible asset which transferred from the predecessor to the successor on the transfer of the trade, and

(II) the provision of a specified intangible asset which did not so transfer,

when determining the transferable excess interest, the excess interest shall be apportioned on a just and reasonable basis.”.

(2) Subsection (1) shall have effect for accounting periods commencing on or after 1 January 2026 in respect of a transfer of a trade to which section 400(5) of the Principal Act applies which occurs on or after 1 January 2026.

45. Amendment of section 481 of Principal Act (relief for investment in films)

45. (1) Section 481 of the Principal Act is amended—

(a) in subsection (1)—

(i) in the definition of “film corporation tax credit”, by the substitution of “subsections (1B), (1C) and (1D)” for “subsections (1B) and (1C)”, and

(ii) by the insertion of the following definitions:

“ ‘relevant visual effects work’, in relation to a visual effects project, means work consisting of such visual effects processes as may be specified in regulations made under subsection (2E);

‘visual effects’ means the use of computer technology to digitally create or manipulate content whether such content is for inclusion in a film or within filmed footage for inclusion in a film;

‘visual effects project’ means—

(a) a qualifying film—

(i) where production by the qualifying company consists wholly or mainly of relevant visual effects work, and

(ii) in respect of which the eligible expenditure on relevant visual effects work is not less than €1,000,000,

or

(b) a qualifying film in respect of which the qualifying company incurs eligible expenditure of not less than €1,000,000 on relevant visual effects work;”,

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

“(1D) (a) Where a producer company expects a film to be a visual effects project, the producer company, in making its application under subsection (1A), may apply for the certificate mentioned in that subsection to specify, in addition to that mentioned in that subsection, that an increased film corporation tax credit (in this section referred to as the ‘enhanced credit amount for visual effects’) may apply as provided for in paragraph (c).

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

(c) Where—

(i) the certificate issued under subsection (2) specifies that the enhanced credit amount for visual effects may apply,

(ii) on completion of production, the qualifying film satisfies the conditions and obligations required by this section, and

(iii) the qualifying film is a visual effects project,

then, subject to paragraph (d), the producer company shall—

(I) in making the claim for the film corporation tax credit under subsection (2G)(b)(ii), calculate the value of the enhanced credit amount for visual effects as if, in the definition, in subsection (1), of ‘film corporation tax credit’, ‘40 per cent’ were substituted for ‘32 per cent’ for that purpose, or

(II) where a claim has been made for the film corporation tax credit under subsection (2G)(b)(i), in making the claim for the film corporation tax credit under subsection (2G)(b)(ii), calculate the value of the enhanced credit amount for visual effects as if, in the definition, in subsection (1), of ‘film corporation tax credit’, ‘40 per cent’ were substituted for ‘32 per cent’ for that purpose, less any amount already claimed pursuant to subsection (2G)(b)(i).

(d) Where, in relation to calculating the value of the enhanced credit amount for visual effects under clause (I) or (II), as the case may be, of paragraph (c), in respect of a visual effects project, the lowest of the amounts referred to in paragraphs (a) to (c) of the definition, in subsection (1), of ‘film corporation tax credit’ (referred to in this paragraph as the ‘qualifying amount’) exceeds €10,000,000, then the total value of the film corporation tax credit for the visual effects project shall comprise—

(i) an enhanced credit amount for visual effects equal to 40 per cent of €10,000,000, and

(ii) an amount equal to 32 per cent of the amount by which the qualifying amount exceeds €10,000,000.”,

(c) in subsection (2)—

(i) in paragraph (a), by the substitution of the following subparagraph for subparagraph (ii):

“(ii) specifying—

(I) whether or not the regional film development uplift applies, if appropriate,

(II) whether or not the enhanced credit for lower budget film may apply, if appropriate, or

(III) whether or not the enhanced credit amount for visual effects may apply, if appropriate.”,

and

(ii) in paragraph (b)—

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

(II) in subparagraph (v), by the substitution of “if appropriate, and” for “if appropriate”, and

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

“(vi) the criteria referred to in subsection (1D)(b), if appropriate,”,

and

(d) in subsection (2E)—

(i) by the insertion of the following paragraph after paragraph (ba):

“(bb) specifying the visual effects processes that may be regarded as relevant visual effects work for the purposes of an application for, and certification in respect of, the enhanced credit amount for visual effects in accordance with this section,”,

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

“(ia) in relation to the matters referred to in the definition, in subsection (1), of ‘visual effects project’, governing the eligible expenditure incurred by the qualifying company on relevant visual effects work for the purposes of the calculation of the enhanced credit amount for visual effects in accordance with this section,”,

and

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

“(lc) specifying the criteria to be considered by the Minister, in relation to the criteria referred to in subsection (1D)(b)—

(i) in deciding whether, in the certificate applied for under subsection (1A), he or she should specify that the enhanced credit amount for visual effects may apply, and

(ii) in specifying conditions in such a certificate, as provided for in subsection (2)(b),

and the information required for those purposes to be included in the application made to the Minister under subsection (1A) by a producer company,”.

(2) Subsection (1) shall apply to a qualifying film (within the meaning of section 481 of the Principal Act) in respect of which the Minister for Culture, Communications and Sport issues a certificate (within the said meaning) after the coming into operation of this section.

(3) This section shall come into operation on such day as the Minister for Finance may, by order, appoint.

46. Amendment of section 481A of Principal Act (relief for investment in digital games)

46. (1) Section 481A of the Principal Act is amended—

(a) in subsection (1)—

(i) by the substitution of the following definition for the definition of “date of completion”:

“ ‘date of completion’ means—

(a) in the case of a qualifying digital game in respect of which a post-release extension of an interim certificate has not been granted, the earlier of—

(i) the date on which the game is first made available to the public, or

(ii) where the game is commissioned by an undertaking other than the digital games development company, the date on which the game is first provided by the digital games development company to the undertaking,

and

(b) in the case of a qualifying digital game in respect of which a post release extension of an interim certificate has been granted, the earlier of—

(i) the last date on which post-release digital content is made available to the public before an application for a final certificate is made by the digital games development company, or

(ii) where the game is commissioned by an undertaking other than the digital games development company, the last date on which post-release digital content is provided by the digital games development company to the undertaking before an application for a final certificate is made by the digital games development company,

and ‘completed’ shall be construed accordingly;”,

(ii) in the definition of “eligible expenditure”, by the substitution of “an EEA state” for “the EEA”,

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

“ ‘qualifying expenditure’, in relation to an interim digital game or a qualifying digital game, is expenditure (the types of which are specified in regulations made under subsection (17)) incurred by a digital games development company on the design, production and testing of a digital game, being expenditure which for corporation tax purposes is allowable as a deduction in computing, or against, the income of the trade referred to in paragraph (b) of the definition, in this subsection, of ‘digital games development company’ which is chargeable under Case I of Schedule D;”,

and

(iv) by the insertion of the following definitions:

“ ‘date of release’, in relation to an interim digital game, means the date on which the game is first made available to the public and ‘released’ shall be construed accordingly;

‘EEA Agreement’ means the Agreement on the European Economic Area signed at Oporto on 2 May 1992 as adjusted by all subsequent amendments to that Agreement;

‘EEA state’ means a state, other than the State, which is a contracting party to the EEA Agreement;

‘post-release digital content’, in relation to a qualifying digital game, means digital content which is developed subsequent to the date of release of the game and which is in addition to, and for incorporation into, that game;

‘post-release extension of an interim certificate’ shall be construed in accordance with subsection (8A);

‘post-release interim certificate extension period’ has the meaning given to it by subsection (8A);”,

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

“(2) Subject to the provisions of this section, a digital games development company that intends to make a claim for an interim digital games corporation tax credit or a digital games corporation tax credit, as the case may be, under this section—

(a) shall, in relation to a digital game that is to be developed by the company, make an application to the Minister for the issue by the Minister of an interim certificate,

(b) may, in relation to a digital game that is developed by the company and released and in respect of which an interim certificate has been issued under subsection (4), make an application to the Minister for the grant by the Minister of a post-release extension of an interim certificate, and

(c) shall, in relation to a digital game that has been developed and completed by the company and in respect of which an interim certificate has been issued under subsection (4), make an application to the Minister for the issue of a final certificate.”,

(c) in subsection (3), by the substitution of “an interim certificate, a post-release extension of an interim certificate or a final certificate under subsection (2)” for “an interim or final certificate under subsection (2)”,

(d) in subsection (5)—

(i) in paragraph (a), by the deletion of “and”,

(ii) in paragraph (b)—

(I) by the substitution of “the State or an EEA state” for “Ireland or another EEA state” in each place where it occurs, and

(II) in subparagraph (v), by the substitution of “minimising climate change, and” for “minimising climate change.”,

and

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

“(c) the timing of the application for the interim certificate by reference to the date on which the digital games development company first incurs qualifying expenditure on the development of the digital game.”,

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

“(8) On the expiry of an interim certificate, the interim certificate shall cease to have effect and is treated as never having had effect unless—

(a) an application has been made before the expiry date to the Minister under paragraph (b) or (c) of subsection (2), as the case may be, and

(b) on the determination of the application—

(i) in the case of an application under subsection (2)(b), a post release extension of an interim certificate is granted by the Minister, or

(ii) in the case of an application under subsection (2)(c), a final certificate is issued by the Minister.”,

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

“(8A) (a) The Minister may, following an application by a digital games development company under subsection (2)(b), subject to subsection (8B) and in accordance with regulations made under subsection (17), grant to the digital games development company a post-release extension of an interim certificate for such period as the Minister may specify (in this section referred to as the ‘post-release interim certificate extension period’).

(b) Where the Minister grants a post-release extension of an interim certificate under paragraph (a)—

(i) the interim certificate as issued under subsection (4) is extended accordingly,

(ii) the digital game concerned is to be treated as if it were an interim digital game for the purposes of this section, and

(iii) the conditions specified in the interim certificate concerned—

(I) continue to apply, and

(II) may be amended, revoked or added to by the Minister.

(8B) In considering whether to grant a post-release extension of an interim certificate, the Minister shall have regard to the following criteria—

(a) whether the digital game as released is an eligible digital game,

(b) the contribution which the digital game makes to the promotion and expression of Irish or European culture, by reference to the matters referred to in subparagraphs (i) to (v) of subsection (5)(b), and

(c) whether the conditions specified in the interim certificate have, at the date of release of the digital game, been satisfied.

(8C) On the expiry of a post-release interim certificate extension period, the interim certificate shall cease to have effect and is treated as never having had effect unless—

(a) an application has been made to the Minister under subsection (2)(c) before the date on which the post-release interim certificate extension period expires, and

(b) on the determination of that application, a final certificate is issued by the Minister.

(8D) For the purposes of subsection (8A)(b)(iii)(II), subsection (7) shall apply during the post-release interim certificate extension period as it did before the post-release interim certificate extension period.”,

(g) in subsection (9), by the substitution of “subsection (2)(c)” for “subsection (2)(b)”,

(h) in subsection (10), by the substitution of the following paragraph for paragraph (c):

“(c) whether the conditions specified in the interim certificate issued in respect of the interim digital game have been satisfied.”,

(i) in subsection (13)—

(i) in paragraph (b), by the substitution of “the interim certificate or, where a post release extension of an interim certificate has been granted, the post release interim certificate extension period, has expired” for “the interim certificate has expired”, and

(ii) in paragraph (g), by the deletion of “other than the State”,

(j) in subsection (14A)(c), by the substitution of “section 481, or” for “section 481, and”,

(k) in subsection (15)(c), by the deletion of “the Revenue Commissioners may”,

(l) in subsection (16)—

(i) in paragraph (a)(i)(I), by the substitution of “the State or an EEA state” for “an EEA state”,

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

“(ba) in relation to a claim under subsection (19) as respects an interim digital game that is released, where the company fails to provide, when requested to do so by the Revenue Commissioners, for the purposes of verifying compliance with the provisions governing the relief or with any condition specified in a certificate issued by the Minister under subsection (4), a copy of a released digital game, in such format and manner as is required to be provided to the Minister under paragraph (d)(ii) as respects a completed digital game,”,

and

(iii) by the substitution of the following paragraph for paragraph (e):

“(e) unless—

(i) the company makes a claim under subsection (20) and has available, prior to making that claim, a compliance report, in such format and manner as is specified in the regulations made under subsection (17), which provides proof that—

(I) the provisions of this section in so far as they apply in relation to the company have been met,

(II) any conditions attaching to the interim certificate issued to the company in relation to the interim digital game have been fulfilled, and

(III) any conditions attaching to the final certificate issued to the company in relation to the qualifying digital game have been fulfilled,

or

(ii) the requirements of subparagraphs (i) to (iii) of subsection (28A)(c) are satisfied in respect of the company,”,

(m) in subsection (17)—

(i) in paragraph (a), by the substitution of “interim certification, post-release extension of an interim certificate and final certification” for “interim certification or final certification”, and

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

“(ba) specifying, in relation to an application for a post-release extension of an interim certificate, the time within which, and the format, number of copies and manner in which, a released digital game shall be provided to the Minister,

(bb) specifying, in relation to an application for a post-release extension of an interim certificate, the time within which a digital games development company shall notify the Minister of the date of release of a released digital game,

(bc) specifying the time within which, and the format and manner in which, the confirmation referred to in subsection (28A)(c)(i) shall be sought and the information and documents to be provided to the Minister,”,

and

(iii) in paragraph (g), by the substitution of “in accordance with subsection (16)(e)(i) or (28A)(c)(ii)” for “in accordance with subsection (16)(e)”,

(n) in subsection (19)(b), by the substitution of “the interim certificate or the post release interim certificate extension period, as the case may be, has not expired” for “the interim certificate has not expired”,

(o) in subsection (26)(a), by the substitution of “in respect of which an amount was paid or offset under subsection (22)” for “in respect of which the payment was made”,

(p) by the insertion of the following subsection after subsection (28):

“(28A) (a) This subsection applies to a claim for the interim digital games corporation tax credit where—

(i) the amount was claimed under subsection (19), or paid or offset under subsection (22A), and

(ii) the interim certificate is subsequently treated under subsection (8) or (8C), as the case may be, as ceasing to have effect and never having had effect.

(b) Subject to paragraph (c), where this subsection applies, any amount that is to be charged to tax in accordance with subsection (26) may be so charged within 4 years of the end of the accounting period in which the interim certificate is first treated under subsection (8) or (8C), as the case may be, as ceasing to have effect and never having had effect at any time.

(c) Where the interim certificate is treated under subsection (8C) as never having had effect, then notwithstanding the generality of subsection (26), the amount that is to be charged to tax in accordance with that subsection shall, subject to paragraph (d), be the amount of the interim digital games corporation tax credit that was claimed under subsection (19), or paid or offset under subsection (22A), as the case may be, in respect of expenditure incurred on the development of the interim digital game after the date of release provided that—

(i) the Minister confirms that a final certificate would have been issued to the digital games development company in accordance with subsection (9) if, when the company made the application to the Minister for a post-release extension of an interim certificate under subsection (2)(b), the company had, instead, made an application to the Minister for a final certificate under subsection (2)(c),

(ii) the digital games development company has available a compliance report, in such format and manner as is specified in the regulations made under subsection (17), in respect of any amount of the interim digital games corporation tax credit claimed under subsection (19), or paid or offset under subsection (22A), as the case may be, to the extent that such amount is in respect of the development of the game prior to the date of release, which provides proof of the matters set out in clauses (I) and (II) of subsection (16)(e)(i), and

(iii) as respects the amount of the interim digital games corporation tax credit claimed under subsection (19), the qualifying expenditure incurred by the company on the development of the released game is not less than €100,000.

(d) Nothing in paragraph (c) shall prevent the charging to tax of an amount in accordance with subsection (26) equal to so much of the amount of the interim digital games corporation tax credit that was claimed under subsection (19), or paid or offset under subsection (22A), as the case may be, in respect of expenditure incurred on the development of the interim digital game prior to the date of release as is not as authorised by this section.”,

(q) by the substitution of the following subsection for subsection (29):

“(29) Notwithstanding section 851A, where a digital games development company obtains relief under this section, the Revenue Commissioners may disclose the following taxpayer information in accordance with State aid transparency requirements:

(a) the name of the company;

(b) the name of the digital game;

(c) the number of the certificate of incorporation of the company;

(d) in respect of the principal activity carried on by the company, the NACE classification code, as determined in accordance with Regulation (EC) No. 1893/2006 of the European Parliament and of the Council of 20 December 2006[^15] as amended by Regulation (EU) 2019/1243 of the European Parliament and of the Council of 20 June 2019[^16] and Commission Delegated Regulation (EU) 2023/137 of 10 October 2022[^17];

(e) the amount of interim digital games corporation tax credit or digital games corporation tax credit, as the case may be, granted, by reference to ranges set out in page 10, paragraph 52(7) of the Communication from the Commission (2013/C 332/01)[^18], inserted by Communication from the Commission (2014/C 198/02)[^19];

(f) whether the company is—

(i) a category of enterprise referred to in Article 2.1 of Annex 1 to Commission Regulation (EU) No. 651/2014 of 17 June 2014[^20], or

(ii) a category of enterprise which is larger than the categories of enterprise referred to in subparagraph (i);

(g) the territorial unit, within the meaning of the NUTS Level 2 classification specified in Annex 1 to Regulation (EC) No. 1059/2003 of the European Parliament and of the Council of 26 May 2003[^21] as amended by Regulation (EC) No. 1888/2005 of the European Parliament and of the Council of 26 October 2005[^22], Commission Regulation (EC) No. 105/2007 of 1 February 2007[^23], Regulation (EC) No. 176/2008 of the European Parliament and of the Council of 20 February 2008[^24], Regulation (EC) No. 1137/2008 of the European Parliament and of the Council of 22 October 2008[^25], Commission Regulation (EU) No. 31/2011 of 17 January 2011[^26], Council Regulation (EU) No. 517/2013 of 13 May 2013[^27], Commission Regulation (EU) No. 1319/2013 of 9 December 2013[^28], Commission Regulation (EU) No. 868/2014 of 8 August 2014[^29], Commission Regulation (EU) No. 2016/2066 of 21 November 2016[^30], Regulation (EU) 2017/2391 of the European Parliament and of the Council of 12 December 2017[^31], Commission Delegated Regulation 2019/1755 of 8 August 2019[^32], and Commission Delegated Regulation (EU) 2023/674 of 26 December 2022[^33] in which the company is located;

(h) the date on which the interim digital games corporation tax credit or digital games corporation tax credit, as the case may be, is granted.”,

and

(r) in subsection (31), by the substitution of “31 December 2031” for “31 December 2025”.

(2) (a) (i) The provisions of subsection (1) referred to in subparagraph (ii) shall apply to an application made to the Minister for Culture, Communications and Sport for the grant by that Minister of a post-release extension of an interim certificate, where such application is made on or after the date of the coming into operation of the provisions referred to in subparagraphs (i) to (xiv) of paragraph (c), in respect of—

(I) an extant interim certificate issued in respect of a digital game before the coming into operation of the provisions referred to in subparagraphs (i) to (xiv) of paragraph (c) and in respect of which digital game, on the date on which the application for the grant of a post-release extension of an interim certificate is made, a final certificate has not issued, and

(II) an interim certificate issued on or after the date on which the provisions referred to in subparagraphs (i) to (xiv) of paragraph (c) come into operation.

(ii) The provisions of subsection (1) referred to in subparagraph (i) are as follows:

(I) subparagraph (i) of paragraph (a),

(II) subparagraph (iv) (in so far as that subparagraph inserts the definitions of “date of release”, “post-release digital content”, “post-release extension of an interim certificate” and “post-release interim certificate extension period” in section 481A(1) of the Principal Act) of paragraph (a),

(III) paragraph (b) (in so far as that paragraph substitutes subsection (2)(b) of section 481A of the Principal Act),

(IV) paragraph (c),

(V) paragraph (e),

(VI) paragraph (f),

(VII) subparagraph (i) of paragraph (m), and

(VIII) subparagraph (ii) (in so far as that subparagraph inserts paragraphs (ba) and (bb) in section 481A(17) of the Principal Act) of paragraph (m).

(b) The following provisions of subsection (1) shall apply as respects digital games the development of which begins on or after the date on which those provisions come into operation:

(i) paragraph (b) (in so far as that paragraph substitutes paragraphs (a) and (c) of section 481A(2) of the Principal Act),

(ii) subparagraphs (i), (ii)(II) and (iii) of paragraph (d), and

(iii) paragraph (h).

(c) The following provisions of subsection (1) shall come into operation on such day or days as the Minister for Finance may, by order or orders, appoint and different days may be appointed for different purposes or different provisions:

(i) subparagraph (i) of paragraph (a),

(ii) subparagraph (iv) (in so far as that subparagraph inserts the definitions of “date of release”, “post-release digital content”, “post-release extension of an interim certificate” and “post-release interim certificate extension period” in section 481A(1) of the Principal Act) of paragraph (a),

(iii) paragraph (b),

(iv) paragraph (c),

(v) subparagraphs (i), (ii)(II) and (iii) of paragraph (d),

(vi) paragraph (e),

(vii) paragraph (f),

(viii) paragraph (g),

(ix) paragraph (h),

(x) subparagraph (i) of paragraph (i),

(xi) subparagraphs (ii) and (iii) of paragraph (l),

(xii) paragraph (m),

(xiii) paragraph (n),

(xiv) paragraph (p), and

(xv) paragraph (r).

(3) Paragraphs (a)(iii) and (j) of subsection (1) shall apply as respects claims for the interim digital games corporation tax credit and the digital games corporation tax credit in accordance with section 481A of the Principal Act made on and from the date of the passing of this Act.

47. Amendment of section 831B of Principal Act (participation exemption for certain foreign distributions)

47. (1) Section 831B of the Principal Act is amended—

(a) in subsection (1)—

(i) by the substitution of the following definition for the definition of “relevant subsidiary”:

“ ‘relevant subsidiary’, in relation to a relevant distribution, means a company that—

(a) is, on the date on which it makes the relevant distribution—

(i) by virtue of the law of a relevant territory, resident for the purposes of foreign tax in the relevant territory, and

(ii) not generally exempt from foreign tax,

(b) throughout the relevant period—

(i) was—

(I) by virtue of the law of a relevant territory, resident for the purposes of foreign tax in the relevant territory, and

(II) not generally exempt from foreign tax,

or

(ii) was resident in the State,

(c) did not, at any time during the reference period, make an excluded acquisition, and

(d) was not formed through a merger at any time during the reference period, where a party to the merger was another company (in this paragraph referred to as ‘the second-mentioned company’) that was not resident in the State or that was not, by virtue of the law of a relevant territory, resident for the purposes of foreign tax in a relevant territory—

(i) from the date the reference period commences until the date the merger takes place, or

(ii) where the second-mentioned company was incorporated or formed during the reference period, from the date the second mentioned company was incorporated or formed until the date the merger takes place;”,

(ii) by the insertion of the following definitions:

“ ‘excluded acquisition’ means an acquisition by a company of—

(a) another business or part of another business, or

(b) the whole or greater part of the assets used for the purposes of another business,

where the business concerned was previously carried on by another company (in this definition referred to as ‘the second-mentioned company’) that was not resident in the State or that was not, by virtue of the law of a relevant territory, resident for the purposes of foreign tax in a relevant territory—

(i) from the date the reference period commences until the date the acquisition takes place, or

(ii) where the second-mentioned company was incorporated or formed during the reference period, from the date the second-mentioned company was incorporated or formed until the date the acquisition takes place,

but does not include the acquisition by a company of share capital in another company;

‘foreign withholding tax’ means a tax which—

(a) is directly chargeable on a distribution made by a company that is, by virtue of the law of a territory other than the State, resident for the purposes of foreign tax in that territory, to a company that is not so resident, whether by charge to tax, deduction of tax at source or otherwise, and

(b) is imposed at a nominal rate greater than zero per cent;”,

(iii) in the definition of “reference period”, by the substitution of “3 years” for “5 years”,

(iv) in the definition of “relevant distribution”—

(I) in paragraph (b)(ii), by the insertion of “where subparagraph (i) does not apply,” before “out of the assets of the relevant subsidiary”, and

(II) in clause (I), by the insertion of “other than a tax that is similar or corresponds to the surcharge referred to in section 440 and which is imposed on a company where the greater part of the issued share capital of the company or the greater part of the voting power in the company is held by 5 or fewer individuals” after “the law of that territory”,

(v) in the definition of “relevant period”, in paragraph (a)(i), by the substitution of “3 years” for “5 years”, and

(vi) in the definition of “relevant territory”—

(I) in paragraph (b), by the substitution of “have been made,” for “have been made, or”,

(II) in paragraph (c), by the substitution of “the force of law, or” for “the force of law,”, and

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

“(d) not being a territory referred to in paragraph (a), (b) or (c), a territory (referred to in this section as a ‘specified territory’) which generally imposes a foreign withholding tax on distributions,”,

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

“(1A) For the purposes of the definition, in subsection (1), of ‘relevant territory’, a territory referred to in paragraph (b) or (c), as the case may be, of that definition shall be regarded as a relevant territory from the date that is 3 years immediately preceding the date on which the arrangements referred to in the said paragraph (b) or (c), as the case may be, have been made.”,

(c) in subsection (5)—

(i) in paragraph (a), by the substitution of “the relevant distribution is made,” for “the relevant distribution is made, and”,

(ii) in paragraph (b)—

(I) by the insertion of “other than out of the profits (within the meaning of section 21B(1)(a)) of the relevant subsidiary,” before “where any gain”, and

(II) by the substitution of “section 626B, and” for “section 626B.”,

and

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

“(c) if the relevant subsidiary that makes the relevant distribution is, by virtue of the law of a specified territory, resident for the purposes of foreign tax in the specified territory on the date on which it makes the relevant distribution, where foreign withholding tax has been paid by the relevant subsidiary on the full amount of the relevant distribution and has not been and does not fall to be repaid, in whole or in part, to any person.”,

and

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

“(9) For the purposes of this section, where the law of a relevant territory does not determine the residence of a company for the purposes of foreign tax and the company is not resident for the purposes of foreign tax in another relevant territory by virtue of the law of that other relevant territory, then—

(a) that company shall be regarded as resident for the purposes of foreign tax in the relevant territory where that company is regarded as so resident for the purposes of any arrangements having the force of law by virtue of section 826(1), and

(b) that company shall be regarded as not generally exempt from foreign tax where that company is not generally exempt from a tax which—

(i) corresponds to corporation tax in the State,

(ii) generally applies to income, profits and gains arising in the relevant territory referred to in paragraph (a), and

(iii) is imposed at a nominal rate greater than zero per cent.”.

(2) Subject to subsection (3), subsection (1) shall apply in respect of a relevant distribution (within the meaning of section 831B of the Principal Act) made on or after 1 January 2026.

(3) The following provisions of subsection (1) shall be deemed to apply in respect of a relevant distribution (within the meaning of section 831B of the Principal Act) made on or after 1 January 2025:

(a) paragraph (a)(i);

(b) paragraph (a)(ii), insofar as it relates to the insertion of the definition of “excluded acquisition” in section 831B(1) of the Principal Act.

48. Amendment of section 835AY of Principal Act (interpretation (Part 35D))

48. (1) Section 835AY of the Principal Act is amended, in subsection (1)—

(a) in the definition of “large scale asset”—

(i) in paragraph (i), by the substitution of “section 835AAA(1),” for “section 835AAA(1), or”, and

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

“(k) an electricity transmission infrastructure development, a strategic gas infrastructure development or a strategic infrastructure development, each within the meaning of Part 4 of the Act of 2024, in respect of which a decision to grant permission has been made under section 123 of that Act, or

(l) a large-scale residential development, within the meaning of Part 4 of the Act of 2024, in respect of which a decision to grant permission was made under section 98 or 109 of that Act,”,

and

(b) by the insertion of the following definition:

“ ‘Act of 2024’ means the Planning and Development Act 2024;”.

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

49. Amendment of section 840A of Principal Act (interest on loans to defray money applied for certain purposes)

49. (1) Section 840A of the Principal Act is amended—

(a) in subsection (2), by the substitution of “Subject to subsections (3), (6), (7), (7A) and (8)” for “Subject to subsections (3), (6), (7) and (8)”, and

(b) in subsection (7), by the substitution of the following paragraph for paragraph (a):

“(a) where, other than the holding of shares in an investing company or investing companies, the only business of the first-mentioned company is the on-lending to the investing company or investing companies of moneys which the first-mentioned company has borrowed from persons who are not connected with either or both the first-mentioned company and the investing company or investing companies;”,

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

“(7A) (a) For the purpose of subparagraph (b)(ii)(II), ‘relevant territory’ and ‘tax’ have the same meaning, respectively, as in section 246.

(b) Subject to paragraph (c), subsection (2) shall not apply to an amount of interest on a loan (in this subsection referred to as the ‘connected loan’) made to an investing company by a person who is connected with the investing company (in this subsection referred to as the ‘connected lender’) used in acquiring an asset for the purposes of its trade from a company which, at the time of the acquiring of the asset, was connected with the investing company (in this subsection referred to as the ‘connected seller’), where—

(i) the connected seller had borrowed to acquire the asset such that the interest on the borrowings of the connected seller gave rise to a reduction or relief in computing the amount of profits or gains of the connected seller to be charged to corporation tax under Schedule D, prior to the acquisition of the asset by the investing company,

(ii) the connected lender—

(I) is subject to tax in the State on the interest income in relation to the connected loan, or

(II) by virtue of the law of a relevant territory, is resident in a relevant territory for the purposes of tax and, under the laws of the relevant territory, is subject, without any reduction computed by reference to the amount of such interest, to a tax on the interest income in relation to the connected loan,

and

(iii) it is reasonable to consider that the connected loan is made for bona fide commercial purposes and does not form part of any arrangement or scheme of which the main purpose, or one of the main purposes, is the avoidance of tax.

(c) (i) For the purposes of calculating the amount of interest to which paragraph (b) applies, the principal on the connected loan shall not exceed—

(I) the principal outstanding on the borrowings of the connected seller in respect of the asset concerned at the time immediately prior to the acquisition of the asset by the investing company, or

(II) where subparagraph (ii) applies, the maximum principal amount.

(ii) (I) This subparagraph shall apply where, by virtue of paragraph (b), subsection (2) has not applied to an amount of interest on a connected loan made to a company that is connected with the investing company (referred to in this subparagraph as the ‘previous investing company’) in respect of a previous acquisition of the asset concerned from a company connected with the previous investing company (referred to in this subparagraph as the ‘previous connected seller’).

(II) Where this subparagraph applies, the ‘maximum principal amount’ shall be an amount equal to the principal outstanding on the borrowings of the previous connected seller at the time immediately prior to the acquisition of the asset concerned by the previous investing company and, where there has been more than one previous acquisition referred to in clause (I) in respect of the asset concerned, the maximum principal amount shall be an amount equal to the principal outstanding on the borrowings of the previous connected seller at the time immediately prior to the acquisition of the asset concerned by the previous investing company in the earliest such previous acquisition of the asset concerned to occur.

(iii) For the purposes of calculating—

(I) the principal outstanding on the borrowings of the connected seller in respect of the asset concerned at the time immediately prior to the acquisition of the asset by the investing company, or

(II) where subparagraph (ii) applies, the maximum principal amount,

where only a portion of the borrowings relate to the asset that is acquired by the investing company, then the principal outstanding on the borrowings or the maximum principal amount shall be apportioned on a just and reasonable basis.

(2) Subsection (1) shall apply to an acquisition of an asset (within the meaning of section 840A of the Principal Act) on or after 1 January 2024.

50. Amendment of section 891H of Principal Act (country-by-country reporting)

50. (1) Section 891H of the Principal Act is amended—

(a) in subsection (1)—

(i) by the substitution of “ ‘constituent entity’, ‘consolidated financial statements’, ‘MNE group’,” for “ ‘constituent entity’, ‘MNE group’,”,

(ii) by the substitution of the following definition for the definition of “country by-country report”:

“ ‘country-by-country report’, in relation to an MNE group, means a report that contains the information set out in subsection (4) and that has been prepared in accordance with the OECD Report of 2015 and the OECD CbCR Guidance;”,

and

(iii) by the insertion of the following definitions:

“ ‘OECD CbCR Guidance’ means the document entitled OECD (2024), Guidance on the Implementation of Country-by-Country Reporting: BEPS Action 13, OECD, Paris, published by the OECD in May 2024;

‘Directive’ means Council Directive 2011/16/EU of 15 February 2011[^34] as amended by Council Directive 2014/107/EU of 9 December 2014[^35], Council Directive (EU) 2015/2376 of 8 December 2015[^36], Council Directive (EU) 2016/881 of 25 May 2016[^37], Council Directive (EU) 2016/2258 of 6 December 2016[^38], Council Directive (EU) 2018/822 of 25 May 2018[^39], Council Directive (EU) 2020/876 of 24 June 2020[^40], Council Directive (EU) 2021/514 of 22 March 2021[^41], Council Directive (EU) 2023/2226 of 17 October 2023[^42] and Council Directive (EU) 2025/872 of 14 April 2025[^43];”,

and

(b) by the insertion of the following subsections after subsection (11):

“(12) For the purposes of—

(a) determining whether a group is an MNE group, and

(b) preparing a country-by-country report or equivalent country by country report, as the case may be, to be provided to the Revenue Commissioners,

this section and any regulations made under this section shall be construed so as to ensure, as far as practicable, consistency between—

(i) the effect which is to be given to this section and any regulations made under this section, and

(ii) the effect which would be given if the OECD model legislation were to be applied, in accordance with the OECD Report of 2015 and the OECD CbCR Guidance, to—

(I) the determination of whether a group is an MNE group, and

(II) the preparation of a country-by-country report or equivalent country-by-country report, as the case may be, to be provided to the Revenue Commissioners,

other than where such an application of this section and regulations made under this section would be inconsistent with the Directive.

(13) (a) For the purposes of determining whether a group is an MNE group, when applying the €750 million threshold provided for in Article 1.3 of the OECD model legislation—

(i) where the preceding fiscal year of the ultimate parent entity was less than 12 months, the €750 million threshold shall be decreased pro rata,

(ii) where the group (in this subparagraph referred to as ‘the first mentioned group’) existed as part of another group in the preceding fiscal year and the current fiscal year is the first fiscal year that it is no longer part of the other group and exists as an independent group, the first-mentioned group shall be deemed to have had consolidated group revenue of less than €750 million in the preceding fiscal year, and

(iii) subject to paragraph (b), extraordinary income and gains of the group from investment activities shall be included in the consolidated group revenue if such income and gains are presented in the consolidated financial statements of the ultimate parent entity in accordance with the applicable accounting principles under which the consolidated financial statements were prepared.

(b) Paragraph (a)(iii) shall not apply where the ultimate parent entity or surrogate parent entity of the MNE group are tax resident in a jurisdiction which, for the purposes of determining whether there is a requirement for the ultimate parent entity or surrogate parent entity, as the case may be, to file a country-by-country report in that jurisdiction, does not require extraordinary income and gains from investment activities to be included in the consolidated group revenue unless these items are included in revenue in accordance with the applicable accounting principles under which the consolidated financial statements were prepared.”.

(2) Subsection (1) shall apply to accounting periods ending on or after 1 January 2026.

Chapter 6 Capital Gains Tax

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

51. Section 597AA of the Principal Act is amended—

(a) in subsection (3), by the substitution of “Subject to subsections (4) to (4C)” for “Subject to subsection (4)”,

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

“(4) Where a relevant individual makes a disposal or disposals of the whole or part of chargeable business assets in the period beginning on 1 January 2016 and ending on 31 December 2025—

(a) the rate of capital gains tax referred to in subsection (3) shall be chargeable only on so much, if any, of the chargeable gain or chargeable gains accruing, when added to the aggregate amount of any chargeable gain or chargeable gains accruing in respect of any previous disposal or disposals of the whole or part of the chargeable business assets made by the relevant individual in that period, that does not exceed €1,000,000, and

(b) the rate of capital gains tax referred to in section 28(3) shall be chargeable on so much, if any, of the chargeable gain or chargeable gains accruing, when added to the aggregate amount of any chargeable gain or chargeable gains accruing in respect of any previous disposal or disposals of the whole or part of chargeable business assets made by the relevant individual in that period, that exceeds €1,000,000.”,

and

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

“(4A) Subsections (4B) and (4C) shall apply where a relevant individual makes a disposal or disposals of the whole or part of chargeable business assets on or after 1 January 2026, and the amount that is the aggregate of—

(a) the chargeable gain or chargeable gains accruing,

(b) the aggregate amount of any chargeable gain or chargeable gains accruing in respect of any previous disposal or disposals of the whole or part of chargeable business assets made by the relevant individual on or after 1 January 2026, and

(c) the aggregate amount of any chargeable gain or chargeable gains accruing in respect of any previous disposal or disposals of the whole or part of chargeable business assets made by the relevant individual in the period beginning on 1 January 2016 and ending on 31 December 2025, provided that where the chargeable gain or chargeable gains so aggregated for such disposals is greater than €1,000,000, the chargeable gain or chargeable gains that shall be so aggregated in respect of such disposals shall be €1,000,000,

exceeds €1,500,000.

(4B) The rate of capital gains tax referred to in subsection (3) shall be chargeable only on so much, if any, of the chargeable gain or chargeable gains referred to in paragraph (a) of subsection (4A), when added to the amount of any chargeable gain or chargeable gains referred to in paragraphs (b) and (c) of subsection (4A), that does not exceed €1,500,000.

(4C) The rate of capital gains tax referred to in section 28(3) shall be chargeable on so much of the chargeable gain or chargeable gains referred to in paragraph (a) of subsection (4A), when added to the amount of any chargeable gain or chargeable gains referred to in paragraphs (b) and (c) of subsection (4A), that exceeds €1,500,000.”.

52. Amendment of section 604B of Principal Act (relief for farm restructuring)

52. (1) Section 604B(1) of the Principal Act is amended, in paragraph (a)—

(a) by the substitution of the following definition for the definition of “agricultural land”:

“ ‘agricultural land’ means—

(i) land in the State used for the purposes of farming, including land suitable for occupation as woodlands on a commercial basis, and

(ii) land in the State suitable for occupation as woodlands (other than on a commercial basis), used for the purpose of conservation,

but does not include buildings on the land;”,

(b) by the insertion of the following definition:

“ ‘conservation’ has the same meaning as it has in European Communities (Birds and Natural Habitats) Regulations 2011 (S.I. No. 477 of 2011);”,

and

(c) in the definition of “relevant period”, by the substitution of “31 December 2029” for “31 December 2025”.

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

(3) Paragraph (c) of subsection (1) shall come into operation on such day as the Minister for Finance may, by order, appoint.

PART 2 Excise

53. Amendment of Chapter 1 of Part 2 of Finance Act 1999 (Mineral Oil Tax)

53. (1) Chapter 1 of Part 2 of the Finance Act 1999 is amended—

(a) in section 94(1), by the insertion of the following definitions:

“ ‘appropriate procedure’ means—

(a) in relation to biofuel for use as a propellant, and vehicle biogas, the procedure established by the National Oil Reserves Agency under Regulation 4(1) of the European Union (Biofuel Sustainability Criteria) Regulations 2012 (S.I. No. 33 of 2012), and

(b) in relation to biofuel for use other than as a propellant, the procedure established under Regulation 7(1) of the European Union (Renewable Energy) Regulations (2) 2022 (S.I. No. 350 of 2022) by the competent authority referred to in the said Regulation 7(1) or, where no such procedure has been established, the procedure referred to in paragraph (a);

‘sustainability and greenhouse gas emissions saving criteria’ means the sustainability and greenhouse gas emissions saving criteria laid down in Article 29 of Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018[^44];”,

and

(b) in section 100—

(i) in subsection (1), by the substitution of the following paragraph for paragraph (f):

“(f) to be intended solely for use, or to have been solely used, to produce electricity, where that electricity is—

(i) subject to electricity tax under section 58(1) of the Finance Act 2008 or is supplied for consumption outside the State, and

(ii) produced in an installation that is covered by a greenhouse gas emissions permit.”,

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

“(1A) Subject to such conditions as the Commissioners may prescribe or otherwise impose, a relief from mineral oil tax exclusive of the carbon charge, shall be granted on any mineral oil that is shown to the satisfaction of the Commissioners to be intended solely for use, or to have been solely used, to produce electricity, where that electricity is subject to electricity tax under section 58(1) of the Finance Act 2008 or is supplied for consumption outside the State.”,

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

“(5) Subject to such conditions as the Commissioners may prescribe or otherwise impose, a relief from the carbon charge shall apply—

(a) to any mineral oil that is—

(i) shown to the satisfaction of the Commissioners to be biofuel, and

(ii) demonstrated, in accordance with the appropriate procedure, to be in compliance with the sustainability and greenhouse gas emissions saving criteria,

or

(b) where biofuel which meets the requirements of paragraph (a) has been mixed or blended with any other mineral oil, to the biofuel content of any such mixture or blend.”,

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

“(5A) Subject to such conditions as the Commissioners may prescribe or otherwise impose, a relief from the carbon charge shall apply—

(a) to any vehicle gas that is—

(i) shown to the satisfaction of the Commissioners to be vehicle biogas, and

(ii) demonstrated, in accordance with the appropriate procedure, to be in compliance with the sustainability and greenhouse gas emissions saving criteria,

or

(b) where vehicle biogas which meets the requirements of paragraph (a) has been mixed or blended with any other vehicle gas, to the vehicle biogas content of any such mixture or blend.”,

(v) by the insertion of the following subsection after subsection (5A) (amended by subparagraph (iv)):

“(5B) (a) Where—

(i) relief from mineral oil tax has been availed of in respect of biofuel or vehicle biogas in accordance with subsection (5) or (5A), as the case may be, and

(ii) it is determined, in accordance with the appropriate procedure, that the said biofuel or vehicle biogas is not in compliance with the sustainability and greenhouse gas emissions saving criteria,

then, a liability to mineral oil tax, equal to the amount of relief availed of in respect of that biofuel or vehicle biogas, shall arise.

(b) Notwithstanding paragraphs (a) and (b) of section 95(2), where a liability to mineral oil tax arises under paragraph (a) of this subsection, the liability shall apply from the date on which the person who availed of the relief is notified, in accordance with the appropriate procedure, of the determination referred to in the said paragraph (a) of this subsection.”,

and

(vi) in subsection (6)(a), by the insertion of “, other than in the case of mineral oil to which subsection (1)(f) applies,” after “greenhouse gas emissions permit,”.

(2) Subsection (1) shall come into operation on such day or days as the Minister for Finance may, by order, appoint and different days may be so appointed for different purposes or different provisions.

54. Amendment of section 71 of Finance Act 2010 (reliefs from natural gas carbon tax)

54. (1) Section 71 of the Finance Act 2010 is amended—

(a) in subsection (1)(a), by the insertion of “in an installation that is covered by a greenhouse gas emissions permit” after “electricity”, and

(b) in subsection (2), by the insertion of “, other than natural gas to which subsection (1)(a) applies” after “greenhouse gas emissions permit”.

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

55. Amendment of section 82 of Finance Act 2010 (reliefs from solid fuel carbon tax)

55. (1) Section 82 of the Finance Act 2010 is amended—

(a) in subsection (1)(a), by the insertion of “in an installation that is covered by a greenhouse gas emissions permit” after “electricity”, and

(b) in subsection (2)—

(i) by the substitution of “delivered” for “supplied”, and

(ii) by the insertion of “, other than solid fuel to which subsection (1)(a) applies” after “greenhouse gas emissions permit”.

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

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

56. The Finance Act 2005 is amended with effect as on and from 8 October 2025 by the substitution of the following Schedule for Schedule 2:

“SCHEDULE 2

RATES OF TOBACCO PRODUCTS TAX

(With effect as on and from 8 October 2025)