FINANCE ACT 2025

Type Act

Publication 2025-12-23

State In force

Text As published

Source Irish Statute Book

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articles 107

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

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

Reform history JSON API

“ ‘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 2006¹⁵ as amended by Regulation (EU) 2019/1243 of the European Parliament and of the Council of 20 June 2019¹⁶ and Commission Delegated Regulation (EU) 2023/137 of 10 October 2022¹⁷;

(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 2014²⁰, 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 2003²¹ as amended by Regulation (EC) No. 1888/2005 of the European Parliament and of the Council of 26 October 2005²², Commission Regulation (EC) No. 105/2007 of 1 February 2007²³, Regulation (EC) No. 176/2008 of the European Parliament and of the Council of 20 February 2008²⁴, Regulation (EC) No. 1137/2008 of the European Parliament and of the Council of 22 October 2008²⁵, Commission Regulation (EU) No. 31/2011 of 17 January 2011²⁶, Council Regulation (EU) No. 517/2013 of 13 May 2013²⁷, Commission Regulation (EU) No. 1319/2013 of 9 December 2013²⁸, Commission Regulation (EU) No. 868/2014 of 8 August 2014²⁹, Commission Regulation (EU) No. 2016/2066 of 21 November 2016³⁰, Regulation (EU) 2017/2391 of the European Parliament and of the Council of 12 December 2017³¹, Commission Delegated Regulation 2019/1755 of 8 August 2019³², and Commission Delegated Regulation (EU) 2023/674 of 26 December 2022³³ 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.”,

(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;”,

“(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 2011³⁴ as amended by Council Directive 2014/107/EU of 9 December 2014³⁵, Council Directive (EU) 2015/2376 of 8 December 2015³⁶, Council Directive (EU) 2016/881 of 25 May 2016³⁷, Council Directive (EU) 2016/2258 of 6 December 2016³⁸, Council Directive (EU) 2018/822 of 25 May 2018³⁹, Council Directive (EU) 2020/876 of 24 June 2020⁴⁰, Council Directive (EU) 2021/514 of 22 March 2021⁴¹, Council Directive (EU) 2023/2226 of 17 October 2023⁴² and Council Directive (EU) 2025/872 of 14 April 2025⁴³;”,

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

“(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

(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 2018⁴⁴;”,

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)

Description of Product Rate of Tax

Cigarettes .... .... .... .... .... .... .... .... .... Rate of tax at— (a) except where paragraph (b) applies, €483.50 per thousand together with an amount equal to 8.78 per cent of the price at which the cigarettes are sold by retail, or (b) €533.99 per thousand in respect of cigarettes sold by retail where the rate of tax would be less than that rate had the rate been calculated in accordance with paragraph (a).

Cigars .... .... .... .... .... .... .... .... .... .... Rate of tax at €541.758 per kilogram.

Fine-cut tobacco for the rolling of cigarettes .... .... .... .... .... .... .... .... .... Rate of tax at €521.201 per kilogram.

Other smoking tobacco .... .... .... .... .... Rate of tax at €375.847 per kilogram.

”.


Description of Product	Rate of Tax
Cigarettes .... .... .... .... .... .... .... .... ....	Rate of tax at— (a) except where paragraph (b) applies, €483.50 per thousand together with an amount equal to 8.78 per cent of the price at which the cigarettes are sold by retail, or (b) €533.99 per thousand in respect of cigarettes sold by retail where the rate of tax would be less than that rate had the rate been calculated in accordance with paragraph (a).
Cigars .... .... .... .... .... .... .... .... .... ....	Rate of tax at €541.758 per kilogram.
Fine-cut tobacco for the rolling of cigarettes .... .... .... .... .... .... .... .... ....	Rate of tax at €521.201 per kilogram.
Other smoking tobacco .... .... .... .... ....	Rate of tax at €375.847 per kilogram.

57. Amendment of section 64 of Finance Act 2002 (interpretation)

57. (1) Section 64 of the Finance Act 2002 is amended—

(a) by the substitution of the following definition for the definition of “licensed bookmaker”:

“ ‘licensed bookmaker’ means a person who is the holder of a bookmaker’s licence or a remote bookmaker’s licence, as the case may be, or a person who is the holder of a betting licence issued under—

(a) section 85(1)(a) of the Act of 2024,

(b) section 85(1)(b) of the Act of 2024, or

(c) section 85(1)(c) of the Act of 2024;”,

(b) by the substitution of the following definition for the definition of “remote betting intermediary”:

“ ‘remote betting intermediary’ means a person who is the holder of a licence issued under—

(a) section 7C of the Betting Act 1931, or

(b) section 85(1)(d) of the Act of 2024;”,

and

“ ‘Act of 2024’ means the Gambling Regulation Act 2024;”.

(2) 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.

58. Time when duty becomes due

58. The Finance Act 2002 is amended by the substitution of the following section for section 69:

“69. Betting duty and remote betting duty shall become due at the time the bet is entered into by the bookmaker.”.

59. Amendment of section 70 of Finance Act 2002 (returns)

59. Section 70 of the Finance Act 2002 is amended by the substitution of “excise duty under this Chapter” for “betting duty or betting intermediary duty” in both places where it occurs.

60. Amendment of section 71 of Finance Act 2002 (payment of duty with bet)

60. Section 71(1) of the Finance Act 2002 is amended by the substitution of “excise duty” for “betting duty” in both places where it occurs.

61. Amendment of section 77 of Finance Act 2002 (regulations for payment of duty on bets)

61. Section 77(1) of the Finance Act 2002 is amended—

(a) in paragraph (a), by the insertion of “or remote betting intermediaries” after “bookmakers”, and

(b) in paragraph (c), by the deletion of “, remote bookmakers”.

62. De-registration of bookmaking premises

62. (1) The Finance Act 2002 is amended by the substitution of the following section for section 78:

“78. (1) A person who is employed by, or authorised to act as an agent for or on behalf of, a bookmaker shall not engage in any of the following activities:

(a) making any entry on any slip or other record by means of which a bet is made, knowing that the said entry is false;

(b) substituting for any slip or record another document which is false;

(c) making any entry in any book or record kept for the purpose of recording particulars of bets entered into by the bookmaker knowing that the said entry is false;

(d) otherwise knowingly being concerned in the fraudulent evasion or an attempt at evasion of duty.

(2) A person who contravenes subsection (1) shall be guilty of an offence and shall be liable on summary conviction to an excise penalty of €5,000.

(3)

(a) The holder of a bookmaker’s licence shall not, in the course of carrying on business as a bookmaker or acting as a bookmaker, enter into a bet in any premises which are not for the time being registered in the register.

(b) A person who enters into a bet in contravention of this subsection shall, without prejudice to any other penalty to which he or she may be liable, be guilty of an offence and shall be liable on summary conviction to an excise penalty of €5,000.

(c) This subsection shall not apply to a licensed bookmaker who is lawfully carrying on the business of a bookmaker at, or in the precincts of, an authorised racecourse in accordance with the Irish Horseracing Industry Act 1994 , or a greyhound race track or an authorised coursing meeting in accordance with the Greyhound Industry Act 1958.”.

(2) 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.

63. Repeal of Chapter III of Part II of Finance Act 1992 (Amusement Machine Licence Duty)

63. (1) Chapter III of Part II of the Finance Act 1992 is repealed.

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

64. Amendment of section 68A of Finance Act 2002

64. Section 68A of the Finance Act 2002 is amended—

(a) in subsection (1)—

(i) by the substitution of “excise duty under section 67, 67A or 67B, or any combination thereof” for “betting duty under section 67 or betting intermediary duty under section 67B, or both,”, and

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

“(a) that person is a licensed bookmaker or a remote betting intermediary, and”,

and

(b) in subsection (7), by the insertion of the following paragraph after paragraph (iv):

“(v) furnish, by electronic means, a return in respect of the said accounting period in the manner specified in section 70.”.

65. Amendment of section 135 of Finance Act 1992 (temporary exemption from registration)

65. (1) Section 135(aa) of the Finance Act 1992 is amended by the insertion of “or Northern Ireland” after “Member State” in each place where it occurs.

(2) Subsection (1) is deemed to have come into operation on and from 31 December 2020.

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

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

(a) in subsection (3)(b), by the substitution of “31 December 2026” for “31 December 2025”, and

(b) in subsection (4), by the substitution of “31 December 2026” for “31 December 2025”.

PART 3 Value-Added Tax

67. **Definition (Part 3)**

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

68. Persons not accountable persons unless they so elect

68. (1) The Principal Act is amended, with effect from 1 January 2026—

(a) in section 4(1), in paragraph (b) of the definition of “farmer”—

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

“(ii) supplies of services consisting of the training of horses for racing, the total annual turnover for which has not exceeded, in the current calendar year or the previous calendar year, the services threshold;”,

and

(ii) in subparagraph (iii), by the substitution of “annual turnover” for “consideration”,

(b) in section 6—

(i) in subsection (1)—

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

“(a) a farmer, for whose supply, in the current calendar year or the previous calendar year, of—

(i) agricultural services (other than insemination services, stock minding or stock-rearing), the total annual turnover for which has not exceeded the services threshold,

(ii) goods being bovine semen, the total annual turnover for which has not exceeded the goods threshold,

(iii) goods, being horticultural type products of the kind specified in paragraph 22(1) of Schedule 3, to persons who are not engaged in supplying those goods in the course or furtherance of business, the total annual turnover for which has not exceeded the goods threshold,

(iv) either or both services of the kind specified in subparagraphs (i) and (vi), together with any or all goods of the kind specified in subparagraph (v), the total annual turnover for which has not exceeded the services threshold,

(v) any or all goods of the kind specified in subparagraph (ii), subparagraph (iii) where supplied in the circumstances set out in that subparagraph, and subparagraph (vii), the total annual turnover for which has not exceeded the goods threshold,

(vi) agricultural services of the kind specified in an order made under section 86A, the total annual turnover for which has not exceeded the services threshold, or

(vii) agricultural produce of the kind specified in an order made under section 86A, the total annual turnover for which has not exceeded the goods threshold;”,

and

(II) in paragraph (b)(ii)(II), by the substitution of “annual turnover” for “consideration”,

and

(ii) in subsection (2)(c), by the substitution of “subsection (1)(a)(i), (ii), (iii), (vi) or (vii),” for “subsection (1)(a)(i), (ii) or (iii),”,

(c) in section 17(2)(a), by the substitution of “the total annual turnover for which has exceeded, in the current calendar year or the previous calendar year, the services threshold,” for “the consideration for which has exceeded the services threshold in any continuous period of 12 months,”, and

(d) in Part 2 of Schedule 3, in paragraph 12(1A), by the substitution of “where the total annual turnover for providing those facilities exceeds, in the current calendar year or the previous calendar year, the services threshold” for “where the total consideration received by such entity for providing those facilities exceeds, or is likely to exceed, the services threshold during any continuous period of 12 months”.

69. Amendment of section 46 of Principal Act (reduced rate for electricity and gas)

69. Section 46(1) of the Principal Act is amended, in paragraph (caa), by the substitution of “31 December 2030” for “31 October 2025” with effect as on and from 8 October 2025.

70. (1) The Principal Act is amended, with effect as on and from 8 October 2025—

(a) in section 46(1)—

(i) in paragraph (a), by the insertion of “(cab),” after “(caa),”,

(ii) in paragraph (c), by the insertion of “, (cab)” after “(caa)”, and

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

“(cab) during the period from 8 October 2025 to 25 November 2025, 9 per cent in relation to goods of a kind specified in paragraph 9A of Schedule 3 on which tax would, but for this paragraph, be chargeable in accordance with paragraph (c);”,

and

(b) in Schedule 3—

(i) in Part 2, by the insertion of the following paragraph after paragraph 9:

“Housing as part of a social policy.

9A. The supply of housing, as part of a social policy, being the supply of an apartment, used or to be used for residential purposes, in an apartment block within the meaning of section 31E of the Stamp Duties Consolidation Act 1999.”,

and

(ii) in Part 3, by the substitution of the following paragraph for paragraph 14:

“14. Subject to paragraph 9A, the supply of immovable goods used or to be used for residential purposes.”.

(2) The Principal Act is amended, with effect as on and from 26 November 2025—

(a) in section 46(1)—

(i) in paragraph (a) (amended by subsection (1)(a)(i)), by the insertion of “(cac),” after “(cab),”,

(ii) in paragraph (c) (amended by subsection (1)(a)(ii)), by the insertion of “, (cac)” after “(cab)”, and

(iii) by the insertion of the following paragraph after paragraph (cab) (inserted by subsection (1)(a)(iii)):

“(cac) during the period from 26 November 2025 to 31 December 2030, 9 per cent in relation to—

(i) goods of a kind specified in subparagraph (2) of paragraph 9B of Schedule 3, and

(ii) services of a kind specified in subparagraph (3) of paragraph 9B of Schedule 3,

on which tax would, but for this paragraph, be chargeable in accordance with paragraph (c);”,

and

(b) in Schedule 3—

(i) in Part 2—

(I) in paragraph 9(1), by the insertion of “(not being services referred to in paragraph 9B(3))” after “Services”, and

(II) by the insertion of the following paragraph after paragraph 9A (inserted by subsection (1)(b)(i)):

“Supply and construction of housing as part of a social policy.

9B. (1) In this paragraph—

‘apartment block’ means a multi-storey building that comprises, or will comprise, not less than 3 apartments with grouped or common access;

‘completed’ has the same meaning as it has in section 94.

(2) The supply of immovable goods, as part of a social policy, which are or, when completed, will be—

(a) one or more than one apartment, used or to be used for residential purposes, in an apartment block, or

(b) an apartment block, used or to be used for residential purposes, but excluding any part of the apartment block that is not used or to be used for residential purposes.

(3) Services consisting of the development, until completed, of immovable goods to which subparagraph (2) applies.”,

(ii) in Part 3, by the substitution of the following paragraph for paragraph 14 (amended by subsection (1)(b)(ii)):

“Housing.

The supply of immovable goods used or to be used for residential purposes, other than immovable goods to which paragraph 9A or 9B(2), as the case may be, applies.”,

and

(iii) in Part 4, in paragraph 15(2), by the insertion of “or 9B(3)” after “paragraph 9(1)”.

71. Amendment of section 46 of Principal Act (reduced rate for food and drink for human consumption and hairdressing services)

71. Section 46(1) of the Principal Act is amended, with effect from 1 July 2026, by the substitution of the following paragraph for paragraph (cb):

“(cb) 9 per cent in relation to goods or services of a kind specified in paragraphs 3(1), 3(3) and 13(3) of Schedule 3 on which tax would, but for this paragraph, be chargeable in accordance with paragraph (c);”.

72. Amendment of sections 60 and 120 of, and paragraph 11 of Schedule 3 to, Principal Act

72. The Principal Act is amended, with effect from 1 January 2026—

(a) in section 60(1), in the definition of ‘qualifying accommodation’, by the deletion of “or accommodation”,

(b) in section 120(15), by the substitution of the following paragraph for paragraph (a):

“(a) the circumstances, terms and conditions under which (for the purposes of paragraph 11 of Schedule 3) a letting of immovable goods consists of the provision of holiday or guest accommodation,”,

and

“11. Subject to regulations, if any, the letting of immovable goods where the letting consists of the provision of holiday or guest accommodation in—

(a) a hotel,

(b) a guesthouse,

(c) all or part of a house,

(d) all or part of an apartment, or

(e) another establishment,

including the letting of a place in a caravan park or camping site.”.

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

73. Section 86(1) of the Principal Act is amended, with effect from 1 January 2026, by the substitution of “4.5 per cent” for “5.1 per cent”.

74. Amendment of section 96 of Principal Act (waiver of exemption under old rules)

74. Section 96 of the Principal Act is amended—

(a) in subsection (2), by the substitution of “on the date specified in subsection (7A)” for “at the end of the taxable period during which it is cancelled in accordance with subsection (3)”,

(b) in subsection (6)—

(i) by the substitution of “Subsections (6) and (7)” for “Subsections (6) to (12)”, and

(ii) in paragraph (a), by the substitution of “who had a waiver which was cancelled before the date of the passing of the Finance Act 2025” for “who has a waiver”,

“(7A) A waiver which has not been cancelled before the date of the passing of the Finance Act 2025 shall be cancelled on the date of the passing of that Act.

(7B)

(a) This subsection applies to a waiver cancelled by virtue of subsection (7A).

(b) For the purposes of applying Chapter 2 of Part 8, the adjustment period (within the meaning of section 63(1) or, as the context may require, the period to be treated as the adjustment period in accordance with section 95(12)) in relation to the tax chargeable on the landlord’s acquisition or development of a capital good, where that landlord used that capital good in relation to the supply of services to which a waiver applied, shall end on the date specified in subsection (7A).”,

and

(d) by the deletion of subsections (3), (4), (8), (9), (10), (11) and (12).

75. Amendments consequential on amendment of section 96 of Principal Act

75. The Principal Act is amended—

(a) in section 15—

(i) in subsection (5)—

(I) by the deletion of “subject to subsection (6),”, and

(II) by the deletion of “or does not have a waiver of his or her right to exemption from tax in accordance with section 96(2) to (5) still in effect at the time of cessation”,

and

(ii) by the deletion of subsection (6),

and

(b) in section 120(11), by the deletion of paragraph (a).

76. Amendment of section 115 of Principal Act (penalties generally)

76. Section 115(1C) of the Principal Act is amended, with effect from 1 January 2026—

(a) in paragraph (b)—

(i) by the substitution of “section 85C” for “section 85C, 85F or 85G, as the case may be,” and

(ii) by the substitution of “that section” for “the section concerned”,

and

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

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FINANCE ACT 2025

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

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

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

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

Chapter 6 Capital Gains Tax

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

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

PART 2 Excise

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

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

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

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

“SCHEDULE 2

57. Amendment of section 64 of Finance Act 2002 (interpretation)

58. Time when duty becomes due

59. Amendment of section 70 of Finance Act 2002 (returns)

60. Amendment of section 71 of Finance Act 2002 (payment of duty with bet)

61. Amendment of section 77 of Finance Act 2002 (regulations for payment of duty on bets)

62. De-registration of bookmaking premises

63. Repeal of Chapter III of Part II of Finance Act 1992 (Amusement Machine Licence Duty)

64. Amendment of section 68A of Finance Act 2002

65. Amendment of section 135 of Finance Act 1992 (temporary exemption from registration)

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

PART 3 Value-Added Tax

67. Definition (Part 3)

68. Persons not accountable persons unless they so elect

69. Amendment of section 46 of Principal Act (reduced rate for electricity and gas)

70. Amendment of section 46 of, and Schedule 3 to, Principal Act (reduced rate for housing as part of a social policy)

71. Amendment of section 46 of Principal Act (reduced rate for food and drink for human consumption and hairdressing services)

72. Amendment of sections 60 and 120 of, and paragraph 11 of Schedule 3 to, Principal Act

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

74. Amendment of section 96 of Principal Act (waiver of exemption under old rules)

75. Amendments consequential on amendment of section 96 of Principal Act

76. Amendment of section 115 of Principal Act (penalties generally)

67. **Definition (Part 3)**