Finance Act 2025

Type Act

Publication 2025-12-23

State In force

Source Irish Statute Book

articles 107

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

(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.”.

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.

14.

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,

(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):

“(d) (i) A payment service provider who does not comply with section 85F(2) shall be liable to a penalty of €4,000.

(ii) A payment service provider who fails to provide the information contained in the records referred to in section 85F(2) in respect of the calendar quarter to which that information relates (in this subparagraph referred to as the ‘first-mentioned calendar quarter’), in the manner specified in section 85G(a), by the end of the month following each calendar quarter subsequent to the first-mentioned calendar quarter, shall be liable to a further penalty of €4,000 in respect of such failure in respect of each such subsequent calendar quarter after the first-mentioned calendar quarter until the payment service provider provides the information concerned in the manner so specified.”.

77. Amendment of paragraph 6(2) of Schedule 1 to Principal Act (financial services)

77. Schedule 1 to the Principal Act is amended, in Part 2, in paragraph 6(2), by the insertion of the following clause after clause (ed):

“(ee) the automatic enrolment retirement savings system established, maintained and controlled by An tÚdarás Náisiúnta um Uathrollú Coigiltis Scoir as provided for in the Automatic Enrolment Retirement Savings System Act 2024;”.

PART 4 Stamp Duties

78. **Definition (Part 4)**

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

79. Amendment of section 83D of Principal Act (repayment of stamp duty where land used for residential development)

79. (1) The Principal Act is amended—

(a) in section 83D—

(i) in subsection (1)—

(I) in paragraph (a)—

(A) in the definition of “commencement notice”, by the substitution of the following paragraph for paragraph (a):

“(a) a commencement notice within the meaning of article 8 of the Regulations of 1997, or”,

(B) by the substitution of the following definition for the definition of “planning permission”:

“ ‘planning permission’ means a permission within the meaning of the Planning and Development Act 2000 or, as the case may be, the Planning and Development Act 2024;”, and

“ ‘large-scale residential development’ has the same meaning as it has in section 2 of the Planning and Development Act 2000 or, from the date on which section 82 of the Planning and Development Act 2024 comes into operation, as it has in that section;”,

and

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

“(b) References in this section to ‘relevant residential development’ shall be construed—

(i) in a case in which a claim for a repayment under subsection (8) is, pursuant to subsection (7)(b), made in respect of such of the construction operations as for the time being are being carried out pursuant to a particular commencement notice, as references to the residential development that comprises those construction operations, or

(ii) in any other case, as references to the entire residential development concerned.”,

(ii) in subsection (3)—

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

“(a) Subject to the provisions of this section, stamp duty paid on an instrument may be repaid in accordance with this section in relation to the land if construction operations on the land commence pursuant to a commencement notice within the period commencing on the date of execution of the instrument and ending—

(i) where the residential development concerned is a large-scale residential development, on the date that is 36 months after the date of execution, or

(ii) in any other case, on the date that is 30 months after the date of execution.”,

and

(II) by the deletion of paragraph (c),

(iii) by the insertion of the following subsection after subsection (3):

“(3A) (a) Notwithstanding subsection (3)(a), the stamp duty repaid under this section shall be liable to the clawback provided for in subsection (12) if—

(i) the relevant residential development specified in a commencement notice is not completed within the period commencing on the date of the sending by a building control authority, in accordance with article 10(2) or 20A(3)(b), as the case may be, of the Regulations of 1997, of an acknowledgment in relation to that notice (in this subparagraph referred to as the ‘first-mentioned date’) and ending—

(I) where the residential development concerned is a large-scale residential development, on the date that is 36 months after the first-mentioned date, or

(II) in any other case, on the date that is 30 months after the first-mentioned date, and

(ii) when completed, the relevant residential development on the land, being the land to which that relevant residential development relates, is not such that—

(I) at least 75 per cent of the total surface area of that land is occupied by dwelling units, or

(II) the gross floor space of dwelling units amounts to at least 75 per cent of the total surface area of that land,

and subparagraphs (i) and (ii) are subsequently referred to in this section as the conditions for the avoidance of a clawback under this paragraph.

(b) If—

(i) the residential development concerned was carried out in a phased manner such that there were 2 or more commencement notices in respect of the construction operations on the land, and

(ii) the repayment claimed under subsection (8) was not made in respect of such of the construction operations that were carried out pursuant to a particular commencement notice pursuant to subsection (7)(b),

the reference in paragraph (a)(i) to a commencement notice shall be construed as a reference to the last of those commencement notices.”,

(iv) in subsection (4)(a), by the substitution of “(3A)(a)(ii)” for “(3)(c)(ii)”,

(v) in subsection (5)(a)—

(I) in subparagraph (ii), by the substitution of “subsection (3A)(a)” for “paragraph (c) of that subsection”, and

(II) by the substitution of “the period specified in subsection (3)(a), (3A)(a)(i) or (4)(b), as the case may be,” for “the period of 30 months specified in subsection (3)(a) or the period of 30 months specified in subsection (3)(c)(i) or (4)(b)”,

(vi) in subsection (7)(b), by the deletion of “, without prejudice to the accountable person’s right to defer making a claim until completion of the residential development concerned,”,

(vii) in subsection (8), by the substitution of the following paragraph for paragraph (e):

“(e) not be made—

(i) until such time as construction operations have commenced pursuant to a commencement notice, and

(ii) notwithstanding anything in subsection (7)(b), after the expiry of 4 years following the commencement of the period specified in subsection (3A)(a)(i) or, as the case may be, subsection (4)(b).”,

(viii) in subsection (9), by the substitution of “under subsection (3A)(a)” for “under paragraph (c) of subsection (3)”,

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

“(c) not be made where, were repayment to be made, the accountable person would be immediately liable to pay to the Commissioners the stamp duty repaid in accordance with subsection (12)(a).”,

(x) in subsection (12), by the substitution of “the conditions specified in paragraph (a) of subsection (3A) for the avoidance of a clawback under that paragraph” for “the conditions specified in paragraph (c) of subsection (3) for the avoidance of a clawback under that paragraph”, and

(xi) in subsection (18), by the substitution of “31 December 2030” for “31 December 2025”,

and

(b) in section 159A(2)(v), by the substitution of “section 83D(8)(e)(ii)” for “section 83D(10)(c)”.

(2) The amendments effected by subsection (1) shall not apply to any claim for repayment of stamp duty made under section 83D of the Principal Act prior to the coming into operation of this section.

80. Miscellaneous amendments to Principal Act

80. The Principal Act is amended—

(a) by the repeal of section 110A,

(b) in section 125C, by the insertion of the following subsection after subsection (7):

“(8) For the purposes of this section, a reference to a relevant policy shall not include a reference to a policy of insurance, being insurance of a class specified in Part A of Annex I to the European Communities (Life Assurance) Framework Regulations 1994 (S.I. No. 360 of 1994), which provides for—

(a) periodic payments to an individual in the event of loss or diminution of income in consequence of ill health, or

(b) the payment of an amount or amounts to an individual in consequence of ill health, disability, accident or hospitalisation.”,

and

(i) in the Heading “CONVEYANCE or TRANSFER on sale of any property other than stocks or marketable securities or a policy of insurance or a policy of life insurance”, in paragraph (1)(b) by the substitution of the following clause for clause (i):

“

(i) for the consideration which is attributable to residential property other than that referred to in clause (ii) or (iii);	1 per cent of the first €1,000,000 of the consideration, 2 per cent of the next €500,000 of the consideration and 6 per cent of the balance of the consideration thereafter, but where the calculation results in an amount which is not a multiple of €1 the amount so calculated shall be rounded down to the nearest €.

”,

and

(ii) in the heading “LEASE”, in paragraph (3)(a)(i) by the substitution of the following subclause for subclause (I):

“

(I) for the consideration which is attributable to residential property other than that referred to in subclause (II) or (III);	1 per cent of the first €1,000,000 of the consideration, 2 per cent of the next €500,000 of the consideration and 6 per cent of the balance of the consideration thereafter, but where the calculation results in an amount which is not a multiple of €1 the amount so calculated shall be rounded down to the nearest €.

”.

81. Land: special provisions

81. The Principal Act is amended—

(a) in section 31A, by the insertion of the following subsection after subsection (4):

“(5) The contract or agreement referred to in subsection (1) shall be deemed to be executed on the date on which the contract or agreement becomes chargeable with stamp duty in accordance with that subsection.”,

(b) in section 31B, by the insertion of the following subsection after subsection (3):

“(4) The agreement referred to in subsection (2) shall be deemed to be executed on the date on which the agreement becomes chargeable with stamp duty in accordance with that subsection.”,

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

(ii) in paragraph (g), by the substitution of “the instrument,” for “the instrument.”, and

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

“(h) in the case of a contract or agreement, referred to in section 31A, for the sale of an estate or interest in the residential unit, on the date the contract or agreement, as the case may be, is deemed to be executed in accordance with subsection (5) of that section, and

(i) in the case of an agreement for a lease or with respect to a letting, referred to in section 50A, of the residential unit for any term exceeding 35 years, on the date the agreement is deemed to be executed in accordance with subsection (3) of that section.”,

and

(d) in section 50A—

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

“(2) The stamp duty paid on any agreement for a lease or with respect to a letting, in accordance with subsection (1), shall, on an application to the Commissioners and subject to section 159A, be repaid by the Commissioners where it is shown to the satisfaction of the Commissioners that the agreement has been rescinded or annulled.”,

and

(ii) by the insertion of the following subsection after subsection (2):

“(3) The agreement referred to in subsection (1) shall be deemed to be executed on the date on which the agreement becomes chargeable with stamp duty in accordance with that subsection.”.

82. Amendment of Part 7 of Principal Act (Exemptions and Reliefs from Stamp Duty)

82. (1) The Principal Act is amended—

(a) by the repeal of section 86A, and

(b) by the insertion of the following section before section 87:

“Market capitalisation

86B. (1) In this section—

‘Directive’ means Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014[^45] on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU;

‘issuer’ has the meaning given to it by subsection (2)(a)(ii);

‘multilateral trading facility’ has the same meaning as it has in Article 4(1), point (22), of the Directive;

‘notification’ means a notification made under paragraph (a) or (b), as the case may be, of subsection (2);

‘notification date’ shall be construed in accordance with subsection (6);

‘operator’ has the meaning given to it by subsection (2)(a);

‘rate of exchange’ means a rate at which 2 currencies might reasonably be expected to be exchanged for each other by persons dealing at arm’s length;

‘regulated market’ has the same meaning as it has in Article 4(1), point (21), of the Directive;

‘relevant market’ means—

(a) a regulated market,

(b) a multilateral trading facility, or

(c) a market located outside the European Union that is equivalent to a regulated market or multilateral trading facility, as the case may be;

‘relevant securities’ means stocks or marketable securities;

‘valid notification’ shall be construed in accordance with subsection (5).

(2) For the purposes of this section—

(a) where, on 1 December in a particular year—

(i) relevant securities are admitted to trading on a relevant market, whether on or before that date, and

(ii) the closing market capitalisation of the issuer of the relevant securities (in this section referred to as the ‘issuer’) on that date is less than €1 billion,

the operator of the relevant market (in this section referred to as the ‘operator’) or the issuer may, in respect of those relevant securities for that particular year, make a notification to the Commissioners stating the closing market capitalisation of the issuer on that date, or

(b) where, after 1 December in a particular year and before 1 December of the following year—

(i) relevant securities are to be admitted to trading on a relevant market, and

(ii) the expected market capitalisation of the issuer upon admission to the relevant market is less than €1 billion,

the operator or the issuer may, in respect of those relevant securities for that particular year, make a notification to the Commissioners stating the expected market capitalisation of the issuer upon admission to the relevant market.

(3) Where a valid notification in respect of relevant securities for a particular year is made under paragraph (a) or (b), as the case may be, of subsection (2), stamp duty shall not be chargeable on a conveyance or transfer of those relevant securities if—

(a) subject to subsection (4), the conveyance or transfer is executed in the period commencing on the later of—

(i) 1 January of the year following that particular year, or

(ii) 14 days after the notification date,

and ending on 31 December of the year following that particular year, and

(b) at the date of execution of the conveyance or transfer, the relevant securities are admitted to trading on a relevant market.

(4) Where a valid notification in respect of relevant securities for a particular year is made under subsection (2)(b) and the relevant securities are admitted to trading on a relevant market in the period commencing on 2 December and ending on 31 December in that particular year, the period referred to in subsection (3)(a) shall be treated as if it commenced on the later of—

(a) the date of admission to the relevant market, or

(b) 14 days after the notification date.

(5) A notification made in respect of relevant securities for a particular year under paragraph (a) or (b), as the case may be, of subsection (2) shall be a valid notification for the purposes of this section where—

(a) the notification is made in such form and manner as the Commissioners may specify, and

(b) such information, if any, as may reasonably be required by the Commissioners in relation to the notification has been provided to the Commissioners by the operator or the issuer, as the case may be.

(6) For the purposes of this section, the notification date in respect of relevant securities for a particular year is—

(a) where a valid notification in respect of those relevant securities for the particular year is made by either, but not both, the operator or the issuer, the date on which that valid notification is made by the operator or the issuer, as the case may be, in respect of those relevant securities, or

(b) where a valid notification in respect of those relevant securities for the particular year is made by both the operator and the issuer, the date on which the earlier of the valid notifications is made.

(7) The Commissioners shall, as soon as is practicable after a valid notification in respect of relevant securities for a particular year is made, publish details of the information set out in the valid notification and the date on which the valid notification was made.

(8) For the purposes of this section, where the closing market capitalisation or, the expected market capitalisation, as the case may be, of an issuer is in a currency other than the currency of the State, it shall be expressed in terms of the currency of the State by reference to the average rate of exchange of the currency of the State for the other currency for that day.

(9) This section applies as respects conveyances or transfers of relevant securities executed no later than 31 December 2030.”.

(2) Subsection (1) shall come into operation on 1 January 2026.

83. Amendment of section 126AB of Principal Act (further levy on certain financial institutions)

83. Section 126AB of the Principal Act is amended—

(a) in subsection (1), by the substitution of the following definition for the definition of “base year”:

“ ‘base year’ means—

(a) in respect of each of the years 2024 and 2025, the year 2022, and

(b) in respect of the year 2026, the year 2024;”,

(b) in subsection (2), by the substitution of “each of the years 2024 to 2026 (both years inclusive)” for “each of the years 2024 and 2025”, and

“(3) There shall be charged on every statement delivered under subsection (2) a stamp duty of an amount equal to—

(a) for the years 2024 and 2025, 0.112 per cent of the assessable amount shown in the statement, and

(b) for the year 2026, 0.1025 per cent of the assessable amount shown in the statement.”.

84. Levy on authorised insurers

84. (1) The Principal Act is amended—

(a) in section 125A—

(i) in subsection (1), by the substitution of the following definition for the definition of “relevant contract”:

“ ‘relevant contract’ means a contract of insurance (not being an excluded contract of insurance) between an authorised insurer and an individual (in this section referred to as ‘the relevant individual’) which provides for the making of in-patient indemnity payments under the contract and which, in relation to the relevant individual, the spouse or civil partner of the relevant individual, or the children or other dependents of the relevant individual or of the spouse or civil partner of the relevant individual, provides specifically, whether in conjunction with other benefits or not, for the reimbursement or discharge, in whole or in part, of actual health expenses (within the meaning of section 469 of the Taxes Consolidation Act 1997), being a contract of medical insurance;”,

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

“(2) Subject to subsection (7), an authorised insurer shall, in respect of each accounting period and not later than the due date, deliver to the Commissioners a statement showing the number of insured persons in respect of whom a relevant contract was renewed, or entered into, during the accounting period concerned, where the insured person was—

(a) aged less than 18 years on the day the relevant contract was renewed or entered into and the relevant contract provides for non advanced cover,

(b) aged 18 years or over on the day the relevant contract was renewed or entered into and the relevant contract provides for non-advanced cover,

(c) aged less than 18 years on the day the relevant contract was renewed or entered into and the relevant contract provides for advanced cover, and

(d) aged 18 years or over on the day the relevant contract was renewed or entered into and the relevant contract provides for advanced cover.”,

(iii) in subsection (4), by the substitution of “stamp duty” for “duty”,

(iv) in subsection (6), by the substitution of “in addition to the stamp duty” for “in addition to the duty”,

(v) in subsection (9), by the substitution of “Any stamp duty or interest charged under this section, or any penalty applied under section 134A in relation to a statement required to be delivered under this section,” for “The stamp duty, interest and penalty payable under this section”,

(vi) by the deletion of subsections (10) and (11),

(vii) in subsection (12)(a), by the deletion of “by an individual referred to in the definition of ‘insured person’”, and

(viii) by the insertion of the following subsections after subsection (13):

“(14) Where an authorised insurer is required to pay stamp duty pursuant to subsection (4) in relation to an insured person in respect of whom a relevant contract has been renewed or entered into during an accounting period, the authorised insurer may charge to the relevant individual an amount equal to the amount of stamp duty payable.

(15) (a) Where, in respect of any accounting period—

(i) an insured person is included in the number of insured persons shown on a statement delivered to the Commissioners pursuant to subsection (2) by virtue of a relevant contract having been entered into, or renewed, during the accounting period concerned,

(ii) stamp duty is paid by the authorised insurer on the delivery of the statement pursuant to subsection (4), and

(iii) during the period of 12 months commencing on the day the relevant contract was renewed or entered into (in this paragraph referred to as the ‘relevant period’), the insured person ceases to be insured under the relevant contract,

the authorised insurer shall, on a claim being made to the Commissioners in accordance with paragraph (b) and subject to section 159A, be entitled to a repayment of stamp duty determined by the formula—

A X (B)/(12)

where—

A is the amount of stamp duty paid by the authorised insurer, and

B is the number of complete months that remain in the relevant period immediately following the date on which the insured person ceases to be insured under the relevant contract.

(b) A claim for repayment of stamp duty under paragraph (a) shall be made by the authorised insurer in the statement that the authorised insurer is required to deliver to the Commissioners pursuant to subsection (2) in respect of the accounting period during which the insured person ceases to be insured under the relevant contract.

(c) For the purposes of paragraph (a), if, on the date the insured person ceases to be insured under the relevant contract, a person (in this paragraph referred to as ‘the successor’) other than the authorised insurer that delivered the statement to the Commissioners on which the insured person was included carries on the business that required the delivery of that statement, the successor shall be treated as if it were the authorised insurer that delivered the statement.

(16) Without prejudice to section 960H of the Taxes Consolidation Act 1997, where an authorised insurer is entitled to a repayment of stamp duty pursuant to a claim made in accordance with subsection (15), the Collector-General may, instead of making the repayment, set the amount of the repayment against any stamp duty that is payable by the authorised insurer pursuant to subsection (4) in respect of the accounting period during which the insured person ceased to be insured under the relevant contract.

(17) Where, in relation to an insured person—

(a) an authorised insurer is entitled to a repayment of stamp duty pursuant to a claim made in accordance with subsection (15), and

(b) any of the following conditions is satisfied—

(i) the repayment is made to the authorised insurer;

(ii) the Collector-General has, in accordance with subsection (16), set the repayment against stamp duty that is payable by the authorised insurer; or

(iii) the Collector-General has set or withheld the repayment pursuant to section 960H of the Taxes Consolidation Act 1997,

then, the authorised insurer shall, to the extent that the relevant individual paid to the authorised insurer the amount referred to in subsection (14), pay to the relevant individual the amount determined by the formula—

A B + C

where—

A is the amount paid by the relevant individual to the authorised insurer in relation to that insured person in respect of the accounting period pursuant to subsection (14),

B is the amount of stamp duty paid by the authorised insurer in relation to that insured person in respect of the accounting period pursuant to subsection (4), and

C is the amount of the repayment.”,

and

(b) in section 159A(2)(c)—

(i) in subparagraph (vi), by the deletion of “or”,

(ii) in subparagraph (vii), by the substitution of “section 83DB, or” for “section 83DB.”, and

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

“(viii) for the purposes of section 125A(15), the date the insured person (within the meaning of section 125A) ceased to be insured under the relevant contract (within the meaning of section 125A).”.

(2) Subsection (1) shall come into operation on 1 April 2027.

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

85. Section 81AA of the Principal Act is amended, in subsection (16), by the substitution of “31 December 2029” for “31 December 2025”.

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

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

(a) in subsection (1)—

(i) in paragraph (a)—

(I) in the definition of “conditions of consolidation”, by the substitution of “guidelines made and published pursuant to paragraph (b)(i)” for “guidelines”,

(II) in the definition of “consolidation certificate”, by the substitution of “guidelines made and published pursuant to paragraph (b)(i)” for “guidelines”,

(III) by the deletion of the definition of “guidelines”,

(IV) in the definition of “relevant land”, by the substitution of “agricultural land, including woodland, situated in the State” for “agricultural land, including lands suitable for occupation as woodlands on a commercial basis, in the State”,

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

(VI) by the insertion of the following definition:

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

and

(ii) in paragraph (b), by the substitution of “Minister for Agriculture, Food and the Marine” for “Minister for Agriculture and Food”,

(b) in subsection (6), by the substitution of the following paragraph for paragraph (b):

“(b) use the qualifying land—

(i) for farming, or

(ii) in the case of qualifying land consisting of woodland (other than woodland occupied on a commercial basis), for conservation purposes in accordance with guidelines made and published by the Minister for Agriculture, Food and the Marine,”,

and

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

PART 5 Capital Acquisitions Tax

87. **Definition (Part 5)**

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

88. Amendment of section 41 of Principal Act (when interest in assurance policy becomes interest in possession)

88. (1) Section 41 of the Principal Act is amended—

(a) in subsection (1), by the substitution of “Subject to subsection (1A), for the purposes of this Act” for “For the purposes of this Act”, and

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

“(1A) For the purposes of this Act, where an interest in a policy of assurance on human life is disposed of in whole or in part prior to the occurrence of either of the events specified in paragraph (a) or (b) of subsection (1), then the interest or, as the case may be, that part of the interest, is deemed to become an interest in possession at the time of the disposal.”.

(2) Subsection (1) shall apply to a disposal referred to in subsection (1A) (inserted by subsection (1)(b)) of section 41 of the Principal Act made on or after 1 January 2026.

89. Amendment of Chapter 2 of Part 10 of Principal Act (business relief)

89. (1) The Principal Act is amended—

(a) in section 100, by the substitution of the following subsection for subsection (2):

“(2) (a) An asset is an excepted asset in relation to any relevant business property unless it was—

(i) used wholly or mainly for the purposes of the business concerned throughout the whole, or the last 2 years, of the relevant period, or

(ii) subject to paragraph (b), required at the date of a gift or inheritance to be used for a specific purpose of the business concerned within the period of 6 years commencing on that date,

but where the business concerned is carried on by a company which is a member of a group, the use of an asset for the purposes of a business carried on by another company which at the time of the use and immediately prior to the gift or inheritance was also a member of that group is treated as use for the purposes of the business concerned, unless that other company’s membership of the group is to be disregarded under section 99.

(b) Notwithstanding paragraph (a)(ii), where, at the date of a gift or inheritance, an asset is required to be used for a specific purpose of the business concerned within the period of 6 years commencing on that date, but the asset is not so used within that period, it shall be presumed, unless the contrary is shown, that the asset was an excepted asset in relation to any relevant business property and the taxable value of the gift or inheritance shall be determined accordingly.

(c) Where the taxable value of a gift or inheritance is to be determined in accordance with paragraph (b), an additional return shall be delivered to the Commissioners, and any outstanding tax paid, in accordance with section 46(9).”,

and

(b) in section 101, by the substitution of the following subsection for subsection (2):

“(2) (a) The reduction which would fall to be made under section 92 in respect of relevant business property comprised in a gift or inheritance shall cease to be applicable if and to the extent that the property, or any property which directly or indirectly replaces it—

(i) would not be relevant business property (apart from section 94 and the conditions attached to paragraphs (d) and (f) of section 93(1) and other than by reason of bankruptcy or a bona fide winding-up on grounds of insolvency) in relation to a notional gift of such property taken by the same donee or successor from the same disponer at any time within the relevant period, unless it would be relevant business property (apart from section 94 and the conditions attached to paragraphs (d) and (f) of section 93(1)) in relation to another such notional gift taken within a year after the first-mentioned notional gift, or

(ii) is disposed of in whole or in part within the relevant period and the full proceeds of the disposal are not used, within a year after the disposal, to replace the asset disposed of with other property (other than quoted shares or securities or unquoted shares or securities to which section 99(2)(b) relates) which would be relevant business property (apart from section 94 and the condition attached to section 93(1)(d)) in relation to a notional gift of that other property taken by the same donee or successor from the same disponer on the date of the replacement,

and tax is chargeable in respect of the gift or inheritance as if the property were not relevant business property, but—

(I) any land, building, machinery or plant which are comprised in the gift or inheritance, and which qualify as relevant business property by virtue of section 93(1)(e) shall, together with any similar property which has replaced such property, continue to be relevant business property for the purposes of this section for so long as they are used for the purposes of the business concerned, and

(II) this section shall not have effect where the donee or successor dies before the event which would otherwise cause the reduction to cease to be applicable.

(b) For the purposes of paragraph (a)(ii), where less than full consideration is received for the disposal, the full proceeds of the disposal shall be deemed to be an amount equal to the market value of the property disposed of immediately before the disposal.”.

(2) Subsection (1) shall not apply in relation to gifts or inheritances taken before 1 January 2026.

90. Assessment of executors and administrators

90. (1) The Taxes Consolidation Act 1997 is amended—

(a) in section 1048—

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

“(2) Subject to subsection (2A), no assessment under this section shall be made later than 3 years after the expiration of the year of assessment in which the deceased person died in a case in which the grant of probate or letters of administration was made in that year, and no such assessment shall be made later than 2 years after the expiration of the year of assessment in which such grant was made in any other case.”,

and

(ii) by the insertion of the following subsection after subsection (2):

“(2A) (a) In this subsection—

‘applicant’ has the same meaning as it has in the Regulations of 2020;

‘Regulations of 2020’ means the Capital Acquisitions Tax (Electronic Probate) Regulations 2020 (S.I. No. 341 of 2020).

(b) Notwithstanding subsection (2), where, in accordance with paragraph (3) of Regulation 3 of the Regulations of 2020, an applicant is required to rectify a material error or omission in information delivered to the Revenue Commissioners in accordance with paragraph (1) of the said Regulation, an assessment under this section may be made at any time before the expiration of 2 years after the end of the year of assessment in which the material error or omission is so rectified.”,

and

(b) in section 1077D(2), by the substitution of “subsection (2) or (2A), as the case may be,” for “subsection (2)”.

(2) Subsection (1) shall not apply where, in accordance with Regulation 3(3) of the Capital Acquisitions Tax (Electronic Probate) Regulations 2020 (S.I. No. 341 of 2020), an applicant (within the meaning of the said Regulations) rectifies a material error or omission in information delivered to the Revenue Commissioners, in accordance with Regulation 3(1) of the said Regulations, prior to 1 January 2026.

PART 6 Miscellaneous

91. **Definition (Part 6)**

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

92. Implementation of Part I of OECD (2023) International Standards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework

92. Chapter 3 of Part 38 of the Principal Act is amended by the insertion of the following section after section 891H:

“891HA. (1) This section provides for the collection and reporting of certain information by Reporting Crypto-Asset Service Providers in respect of Crypto-Asset Users that are Reportable Users or that have Controlling Persons that are Reportable Persons.

(2) (a) In this section—

‘CARF’ means Part I of the OECD (2023), International Standards for Automatic Exchange of Information in Tax Matters: Crypto Asset Reporting Framework and 2023 update to the Common Reporting Standard published by the Organisation for Economic Cooperation and Development on 8 June 2023;

‘authorised officer’ means an officer of the Revenue Commissioners authorised under subsection (12);

‘reporting period’ means a calendar year;

‘specified return date’ means 31 May in the year following the year in respect of which a return relates.

(b) A word or expression which is used in this section and which is also used in the CARF has, unless the context otherwise requires, the same meaning in this section as it has in the CARF.

(3) A Reporting Crypto-Asset Service Provider that—

(a) carries out Relevant Transactions, and—

(i) is an Entity or individual that is resident in the State for tax purposes,

(ii) is an Entity incorporated in the State, and

(I) has legal personality, or

(II) has an obligation to file tax returns or tax information returns in respect of the income of the Entity,

(iii) is an Entity that has a place of management in the State, or

(iv) is an Entity or an individual that has a regular place of business in the State,

(b) carries out Relevant Transactions in the State through a Branch,

shall register, not later than 31 December in the year in which it first becomes a Reporting Crypto-Asset Service Provider, with the Revenue Commissioners as a Reporting Crypto-Asset Service Provider for the purposes of this section.

(4) A Crypto-Asset Operator, other than one that satisfies the condition in subparagraph (i) of paragraph (a) of subsection (3) that is required to register with the Revenue Commissioners under that paragraph, that satisfies one or more of the conditions in subparagraphs (ii) to (iv) of that paragraph and that satisfies one or more of those conditions under provisions similar to those subparagraphs in force in another Partner Jurisdiction, shall not be required to register with the Revenue Commissioners under that paragraph where that Crypto-Asset Operator elects to register as a Reporting Crypto-Asset Operator in the other Partner Jurisdiction for the purposes of the CARF and notifies that election in writing, on or before the specified return date, to the Revenue Commissioners.

(5) Subject to subsection (6), a Reporting Crypto-Asset Service Provider registered in the State for the purposes of this section shall by the specified return date—

(a) make a return to the Revenue Commissioners, and

(b) provide to a Reportable User a copy of the information contained in that return in respect of the Reportable User.

(6) A return made under subsection (5) shall contain—

(a) the following details in respect of the Reporting Crypto-Asset Service Provider:

(i) the name;

(ii) the address;

(iii) the TIN or equivalent identifying number and country of issuance;

(iv) the electronic addresses, including websites;

(v) the global legal entity identifier, where available,

(b) the following details in respect of Crypto-Asset Users that are Reportable Users:

(i) the name;

(ii) the address;

(iii) the jurisdiction or jurisdictions of residence;

(iv) the TIN, where issued by the relevant Reportable Jurisdiction or where it is required under the domestic law of the relevant Reportable Jurisdiction;

(v) where the Reportable User is an individual, that person’s—

(I) date of birth, and

(II) place of birth, where it is required under the domestic law of the jurisdiction in which that individual is resident,

(i) the following details in respect of the Entity:

(I) the name;

(II) the address;

(III) the jurisdiction of residence;

(IV) the TIN, where issued by the relevant Reportable Jurisdiction or where it is required under the domestic law of the relevant Reportable Jurisdiction,

and

(ii) the following details in respect of each Controlling Person that is a Reportable Person:

(I) the name;

(II) the address;

(III) the jurisdiction of residence;

(IV) the TIN, where issued by the relevant Reportable Jurisdiction or where it is required under the domestic law of the relevant Reportable Jurisdiction;

(V) the date of birth;

(VI) the place of birth, where it is required under the domestic law of the jurisdiction in which that individual is resident;

(VII) the role by virtue of which each Reportable Person is a Controlling Person,

and

(d) in respect of each person to which paragraph (b) or (c) applies, the following details in respect of each type of Relevant Crypto-Asset for which the Reporting Crypto-Asset Service Provider has carried out Relevant Transactions during the reporting period:

(i) the full name of the Relevant Crypto-Asset;

(ii) in respect of acquisitions against Fiat Currency—

(I) the aggregate gross amount paid,