Finance Act 2025

(ii) subject to paragraph (b), all of the qualifying entities of the MNE group, large-scale domestic group or joint venture group, as the case may be, located in the State have financial accounts prepared in accordance with a local accounting standard and the accounting period of all such accounts is the same as the fiscal year of the consolidated financial statements of the MNE group, large-scale domestic group or joint venture group as the case may be, and—

(I) all such constituent entities are required to prepare or use such accounts for the purposes of determining their liability to tax in the State or to comply with any other law of the State, or

(II) such financial accounts are subject to an external financial audit.

(b) For the purposes of paragraph (a)(ii), where a qualifying entity of an MNE group, large-scale domestic group or joint venture group, as the case may be, located in the State has financial accounts prepared in accordance with a local accounting standard, but the accounting period of such financial accounts is not the same as the fiscal year of the consolidated financial statements of the MNE group, large scale domestic group or joint venture group, as the case may be, as a result of—

(i) the qualifying entity being formed or created, or in the case of a permanent establishment being established, during the fiscal year,

(ii) the qualifying entity being liquidated, dissolved or otherwise ceasing to exist during the fiscal year,

(iii) a merger or division, within the meaning, respectively, of section 638A(1), in relation to the qualifying entity during the fiscal year,

(iv) a cross-border merger or cross-border division, both within the meaning, respectively, of the European Union (Cross Border Conversions, Mergers and Divisions) Regulations 2023 (S.I. No. 233 of 2023), or a merger resulting in the formation of a Societas Europaea in accordance with the SE Regulation, in relation to the qualifying entity during the fiscal year, or

(v) the qualifying entity being acquired by the MNE group, large-scale domestic group or joint venture group, as the case may be, during the fiscal year,

then, for the purposes of paragraph (a)(ii), the accounting period of the financial accounts of the qualifying entity shall be deemed to be the same as the fiscal year of the consolidated financial statements of the MNE group, large-scale domestic group or joint venture group, as the case may be, for that fiscal year and, where subparagraph (v) applies, for the fiscal year following the fiscal year in which the qualifying entity is acquired (referred to in this paragraph as ‘the subsequent fiscal year’), the accounting period of the financial accounts of the qualifying entity shall also be deemed to be the same as the fiscal year of the consolidated financial statements of the MNE group, large-scale domestic group or joint venture group, as the case may be, for the subsequent fiscal year.

(c) In this subsection, ‘SE Regulation’ means Council Regulation (EC) No. 2157/2001 of 8 October 2001[^56] on the Statute for a European company (SE), as amended by Council Regulation (EC) No. 885/2004 of 26 April 2004[^57], Council Regulation (EC) No. 1791/2006 of 20 November 2006[^58] and Council Regulation (EC) No. 517/2013 of 13 May 2013[^59].

(3B) (a) Subject to paragraph (b), where any of the qualifying entities of an MNE group, large-scale domestic group or joint venture group, as the case may be, located in the State prepare financial accounts under more than one local accounting standard then, for the purposes of subsection (3A), the financial accounting net income or loss of a constituent entity for the fiscal year shall be determined in accordance with—

(i) the local accounting standard used for the purposes of determining the profits, losses or gains of the qualifying entity for the purposes of Case I or II of Schedule D, or

(ii) where no such profits, losses or gains exist, the local accounting standard used for the preparation of the financial accounts that are annexed to the annual return to be filed with the Registrar in accordance with the Companies Act 2014, for the accounting period which corresponds to the fiscal year.

(b) Where a qualifying entity does not prepare financial accounts—

(i) for the purposes of determining the profits, losses or gains of the qualifying entity for the purposes of Case I or II of Schedule D, or

(ii) that are annexed to the annual return to be filed with the Registrar in accordance with the Companies Act 2014, for the accounting period which corresponds to the fiscal year,

the financial accounting net income or loss of a constituent entity for the fiscal year shall be determined in accordance with subsections (2) and (3).’,”,

(n) in section 111AAI—

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

“(a) is in accordance with the standard template set out in Section IV of Annex VII of the Directive on Administrative Cooperation, and”,

(ii) in subsection (2), by the insertion of the following paragraph after paragraph (c):

“(d) For the purposes of paragraph (b), a top-up tax information return—

(i) shall be prepared in accordance with—

(I) the standard template set out in Section IV of Annex VII of the Directive on Administrative Cooperation, where the ultimate parent entity or designated filing entity, as the case may be, which files the return is located in a Member State, or

(II) the standardised GloBE Information Return set out in the document referred to in paragraph (f) of the definition, in section 111B, of ‘OECD Pillar Two guidance’, where the ultimate parent entity or designated filing entity, as the case may be, which files the return is not located in a Member State,

and

(ii) is not required to contain the information referred to in paragraphs (da) and (e) of subsection (3).”,

(iii) in subsection (3), by the insertion of the following paragraph after paragraph (d):

“(da) where the filing constituent entity is an ultimate parent entity or a designated filing entity, as the case may be—

(i) confirmation that it is such an entity, and

(ii) the identification of the—

(I) relevant sections of the top-up tax information return, and

(II) jurisdictions that the information shall be distributed to,

pursuant to the dissemination approach set out in—

(A) Article 8ae(2) of the Directive on Administrative Cooperation, with respect to information to be exchanged in accordance with that Directive with a jurisdiction that is a Member State, and

(B) the definition of ‘dissemination approach’ in the OECD Pillar Two MCAA, with respect to information to be exchanged in accordance with the OECD Pillar Two MCAA with a jurisdiction that is not a Member State;”,

and

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

“(9) Notwithstanding section 851A, the Revenue Commissioners are authorised to communicate to the competent authority of a state, other than the State, information which is contained in a top-up tax information return, received pursuant to a filing made in accordance with section 111AAI, provided that there is a qualifying competent authority agreement in place that provides for the exchange of such information.”,

(o) in section 111AAM, by the insertion of the following subsection after subsection (3):

“(4) A notice in writing shall not be served under subsection (3) on a relevant UTPR member that is a securitisation entity where there is at least one other relevant UTPR member of the UTPR group that is not a UTPR group filer and is not a securitisation entity.”,

(p) in section 111AAP, by the insertion of the following subsection after subsection (3):

“(4) A notice in writing shall not be served under subsection (3) on a relevant QDTT member that is a securitisation entity where there is at least one other relevant QDTT member of the QDTT group that is not a QDTT group filer and is not a securitisation entity.”,

and

(q) in section 111AAZ—

(i) by the substitution of the following subsection for subsection (1):

“(1) An entity shall retain, or cause to be retained on behalf of the entity, such records as are required to enable—

(a) a full and true GloBE return, and

(b) a correct and complete top-up tax information return,

to be made for the purposes of this Part.”,

(ii) in subsection (2), by the substitution of “GloBE return, top-up tax information return” for “GloBE return”,

(iii) in subsection (6), by the substitution of “GloBE return, top-up tax information return” for “GloBE return”, and

(iv) by the insertion of the following subsection after subsection (6):

“(7) Sections 900 and 901 shall apply, with any necessary modifications—

(i) to records referred to in subsection (1) as if they were books, records or other documents within the meaning of section 900, and

(ii) to information, explanations and particulars that the authorised officer, within the meaning of those sections, may reasonably require, being information, explanations and particulars which are related to, or in connection with, a GloBE return or top-up tax information return referred to in subsection (1).”.

(2) Subject to subsection (3), subsection (1) shall apply in respect of a fiscal year (within the meaning of section 111A of the Principal Act) or an accounting period, as the case may be, commencing on or after 31 December 2025.

(3) Paragraphs (a), (b)(ii), (c), (d), (e), (g), (h), (i), (j), (k)(i), (k)(ii), (k)(v), (l), (m), (n), (o), (p) and (q) of subsection (1) shall apply in respect of a fiscal year (within the meaning of section 111A of the Principal Act) or an accounting period, as the case may be, commencing on or after 31 December 2023.

96. Amendment of section 638A of Principal Act (company mergers and divisions)

96. (1) Section 638A(2) of the Principal Act is amended by the substitution of “Part 4A, 38” for “Part 38”.

(2) Subsection (1) shall be deemed to have come in to operation on 31 December 2023.

97. Amendment of section 851A of Principal Act (confidentiality of taxpayer information)

97. Section 851A(8) of the Principal Act is amended—

(a) in paragraph (n)—

(i) in subparagraph (i)(II), by the substitution of “Article 108 or 109” for “Article 109”, and

(ii) in subparagraph (ii)(II), by the substitution of “Article 108 or 109” for “Article 109”,

(b) in paragraph (o), by the substitution of the following subparagraph for subparagraph (ii):

“(ii) regulations made pursuant to Article 108 or 109 of the Treaty on the functioning of the European Union,”,

and

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

“(oa) where the taxpayer information is required to be disclosed in accordance with regulations made pursuant to Article 108 or 109 of the Treaty on the functioning of the European Union and is disclosed solely for the purposes of or in connection with the compliance by the State with its obligations under such regulations, and”.

98. Amendment of section 869 of Principal Act (delivery, service and evidence of notices and forms)

98. Section 869(1) of the Principal Act is amended by the insertion of the following paragraph after paragraph (d):

“(e) (i) Without prejudice to paragraphs (b) and (c), a notice under section 879 may be given to an individual by electronic means in accordance with subparagraph (ii) through such online service as may be operated for that purpose by the Revenue Commissioners.

(ii) For the purposes of subparagraph (i), a notice is given to an individual by electronic means in accordance with this subparagraph if—

(I) it is sent to an email address or other electronic contact point at which the individual has agreed in writing to receive the notice, and

(II) a record that the email or other electronic message has been sent is made for the sender by the email system or other electronic system used.”.

99. Amendment of section 959AA of Principal Act (chargeable persons: time limit on assessment made or amended by Revenue officer)

99. Section 959AA of the Principal Act is amended, in subsection (2A), by the substitution of “subsection (1) or (1B), as the case may be, of section 826” for “section 826(1)”.

100. Amendment of section 959AP of Principal Act (payment of preliminary tax by direct debit)

100. Section 959AP of the Principal Act is amended—

(a) in subsection (1)(a), by the deletion of “in accordance with subsection (2)”, and

(b) by the deletion of subsections (2), (3) and (4).

101. Amendment of section 959AU of Principal Act (date for payment of tax: amended assessments)

101. Section 959AU of the Principal Act is amended—

(a) in subsection (1), by the substitution of “subsection (2) or (3), as the case may be,” for “subsection (2)”, and

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

“(3) Where—

(a) an assessment is amended for a second or subsequent time, and

(b) the return, in respect of the chargeable period for which the assessment is amended as referred to in paragraph (a), did not contain a full and true disclosure of all material facts necessary for the making of the assessment,

any additional tax due by reason of the second or subsequent amendment of the assessment shall be deemed to have been due and payable on the same day as the tax due under the assessment before any amendment.”.

102. Amendment of section 959I of Principal Act (obligation to make a return)

102. Section 959I of the Principal Act is amended by the insertion of the following subsection after subsection (5):

“(6) Where a chargeable person as respects a chargeable period prepares and delivers to the Collector-General after the specified return date for the chargeable period a return in the prescribed form, nothing in this Chapter shall operate so as to prevent the chargeable person from making a claim for an allowance, deduction or relief under the Acts in the return, unless a provision of the Acts (other than this subsection) prevents the chargeable person from making a claim for the allowance, deduction or relief where the return is delivered after the specified return date, or the return is delivered later than the date specified by a provision of the Acts (other than this subsection) for making a claim for an allowance, deduction or relief.”.

103. Residential zoned land tax

103. Part 22A of the Principal Act is amended—

(a) in sections 653E, 653I, 653J, 653L, 653AE, 653AF, 653AFA and 653AFB, by the substitution of “An Coimisiún Pleanála” for “An Bord Pleanála” in each place where it occurs,

(b) in section 653A—

(i) in subsection (1)—

(I) by the insertion of the following definition:

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

(II) by the substitution of the following definition for the definition of “local authority consent”:

“ ‘local authority consent’ means—

(a) a notice—

(i) sent in accordance with the procedure outlined in article 84(1) of the Planning and Development Regulations 2001 (S.I. No. 600 of 2001) in respect of local authority own development, as prescribed under section 179 of the Act of 2000 and article 80(1) of those Regulations,

(ii) sent in accordance with the procedure outlined in article 81A of the Planning and Development Regulations 2001 in respect of housing development (within the meaning of section 179A of the Act of 2000),

(iii) published in accordance with section 159(6)(a)(iii) of the Act of 2024 in respect of local authority development of a class prescribed in regulations made under section 153(1) of the Act of 2024, or

(iv) published in accordance with regulations made under subsection (2) of section 161 of the Act of 2024 in respect of local authority housing development (within the meaning of that section),

to indicate that, as the case may be, the local authority will carry out the proposed development or carry out the proposed development subject to variations or modifications,

(b) where paragraph (d) or (e) of section 179(6) of the Act of 2000 applies, an approval granted by An Bord Pleanála in accordance with section 175 or 177AE, as the case may be, of that Act, or

(c) a permission granted by An Coimisiún Pleanála in accordance with Chapter 4 of Part 4 of the Act of 2024 for Chapter 4 Local Authority Development (within the meaning of that Part of that Act);”,

(III) by the substitution of the following definition for the definition of “permission regulations”:

“ ‘permission regulations’ means regulations made under—

(a) section 33, 37I, 43, 172(2), 174, 177N or 177AD of the Act of 2000, or

(b) section 183, 225 or 238 of the Act of 2024;”,

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

“ ‘planning permission’ means a permission granted under—

(a) section 34, 37, 37G, 170 or 177K of the Act of 2000, or

(b) section 98, 109, 123, 124, 131 or 594 of the Act of 2024;”,

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

“ ‘planning permission period’ means—

(a) in relation to a grant of planning permission under the Act of 2000, the appropriate period (within the meaning of section 40 of that Act), including that period as extended in accordance with section 42 of that Act (or that section as modified in accordance with section 42B of that Act), and

(b) in relation to a grant of planning permission under the Act of 2024, the period specified in subsection (1) of section 177 of that Act or in accordance with subsection (3) of that section, as the case may be, including that period as extended in accordance with section 142 or 143 of that Act;”,

and

(VI) by the substitution of the following definition for the definition of “vacant or idle land”:

“ ‘vacant or idle land’ means land which, having regard only to development (within the meaning of the Act of 2000 or, on and from the commencement of Part 4 of the Act of 2024, within the meaning of the Act of 2024) which is not unauthorised development (within the meaning of the Act of 2000 or, on and from the commencement of Part 4 of the Act of 2024, within the meaning of the Act of 2024), is not required for, or integral to, the operation of a trade or profession being carried out on, or adjacent to, the land;”,

and

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

“(3) In this Part, a reference to ‘An Coimisiún Pleanála’ shall be construed as including a reference to ‘An Bord Pleanála’.”,

(c) in section 653B—

(i) in paragraph (a), by the substitution of “a development plan, in accordance with section 10(2)(a) of the Act of 2000 or section 43(6) of the Act of 2024” for “a development plan, in accordance with section 10(2)(a) of the Act of 2000”,

(ii) in paragraph (i), by the substitution of “within the meaning of the Act of 2000 or, on and from the commencement of Part 4 of the Act of 2024, within the meaning of the Act of 2024” for “within the meaning of the Act of 2000” in each place where it occurs, and

(iii) in paragraph (iia)—

(I) in subparagraph (I)—

(A) by the substitution of “zoned in a development plan under the Act of 2000” for “zoned in a development plan”, and

(B) by the substitution of “Act of 2000,” for “Act of 2000, or”,

(II) in subparagraph (II), by the substitution of “Act of 2000, or” for “Act of 2000,”, and

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

“(III) in a case in which the land is zoned in a development plan under the Act of 2024, the order of priority or phasing (where such order of priority or phasing is based on the timing of the provision of any public infrastructure and facilities, as referred to in paragraph (b)), if any, for development indicated in the development plan or an urban area plan, priority area plan or coordinated area plan (in each case within the meaning of the Act of 2024) for an area within which the land is situated.”,

(d) in section 653C(4), by the substitution of the following paragraph for paragraph (f):

“(f) where land is included in a development plan in accordance with section 10(2)(a) of the Act of 2000 or section 43(6) of the Act of 2024, or a local area plan in accordance with section 19(2)(a) of the Act of 2000, zoned—

(i) solely or primarily for residential use, or

(ii) for a mixture of uses, including residential use,

a statement that a person may, in respect of land that such a person owns, make a submission to the local authority requesting a variation of the zoning of that land.”,

(e) in section 653I—

(i) in subsection (1)—

(I) in paragraph (c), by the substitution of “section 653M(1),” for “section 653M(1), or”,

(II) in paragraph (d), by the substitution of “section 653M(1), or” for “section 653M(1),”, and

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

“(e) during the period beginning on 1 February 2026 and ending on 1 April 2026, to a local authority on a revised map for the year 2026 published in accordance with section 653M(1),”,

(ii) in subsection (3), by the substitution of “Subsection (3A) of section 13 of the Act of 2000 or, on and from the commencement of subsection (10) of section 58 of the Act of 2024, that subsection,” for “Subsection (3A) of section 13 of the Act of 2000”,

(iii) in subsection (3A)—

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

“(a) The local authority concerned shall acknowledge, in writing, receipt of a submission to the person who made the submission—

(i) in a case in which the submission is made under subsection (1)(d), not later than 30 April 2025, and

(ii) in a case in which the submission is made under subsection(1)(e), not later than 30 April 2026.”,

and

(II) in paragraph (b)(ii)(I), by the substitution of “section 7 of the Act of 2000 or section 382 of the Act of 2024” for “section 7 of the Act of 2000”,

and

(iv) in subsection (4)—

(I) in paragraph (b), by the substitution of “section 13 of the Act of 2000 or section 58 of the Act of 2024” for “section 13 of the Act of 2000”, and

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

“(c) notify the owner concerned of its decision to—

(i) reject the request for a change to the zoning of lands, or

(ii) propose to make a variation to a development plan under section 13 of the Act of 2000 or section 58 of the Act of 2024,

as follows:

(I) in a case in which a submission is made under subsection (1)(c), not later than July 2024;

(II) in a case in which a submission is made under subsection (1)(d), not later than 30 June 2025;

(III) in a case in which a submission is made under subsection (1)(e), not later than 30 June 2026.”,

(f) in section 653IA—

(i) in subsection (1)(a), by the substitution of “under paragraph (d) or (e) of subsection (1)” for “under subsection (1)(d)”,

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

“(2) Where subsection (1) applies to a relevant site, notwithstanding section 653Q, on the making of a claim by a liable person under this Part in relation to the relevant site, residential zoned land tax shall not be charged and levied in respect of that site—

(a) in a case in which the submission concerned is made under paragraph (d) of section 653I(1), on 1 February 2025, and

(b) in a case in which the submission concerned is made under paragraph (e) of section 653I(1), on 1 February 2026.”,

(iii) in subsection (3)(a), by the substitution of “under paragraph (d) or (e) of subsection (1)” for “under subsection (1)(d)”, and

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

“(5) Where subsection (3) applies to a relevant site, notwithstanding section 653Q, on the making of a claim by a liable person under this Part in relation to the relevant site, residential zoned land tax shall not be charged and levied in respect of the eligible part of the relevant site—

(a) in a case in which the submission concerned is made under paragraph (d) of section 653I(1), on 1 February 2025, and

(b) in a case in which the submission concerned is made under paragraph (e) of section 653I(1), on 1 February 2026.”,

(g) in section 653K—

(i) in paragraph (d)—

(I) in subparagraph (i), by the substitution of “under section 11 of the Act of 2000 or section 42 of the Act of 2024” for “under section 11 of the Act of 2000”, and

(II) in subparagraph (ii), by the substitution of “under section 13 of the Act of 2000 or section 58 of the Act of 2024” for “under section 13 of the Act of 2000”,

(ii) in paragraph (e)—

(I) in subparagraph (i), by the substitution of “pursuant to section 34(12C) of the Act of 2000 or Chapter 3 of Part 4 of the Act of 2024” for “pursuant to section 34(12C) of the Act of 2000”, and

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

“(ii) for substitute consent, in accordance with section 177E of the Act of 2000, or retrospective consent, in accordance with Chapter 4 of Part 4 of the Act of 2024,”,

and

(iii) in paragraph (f), by the substitution of “within the meaning of the Act of 2024” for “within the meaning of the Act of 2000”,

(h) in section 653AE, by the substitution of “section 13 of the Act of 2000 or section 58 of the Act of 2024” for “section 13 of the Act of 2000” in each place where it occurs,

(i) in section 653AF—

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

“(2A) Where this section applies, on the making of a claim by a liable person, any residential zoned land tax that arises in respect of a liability date between—

(a) the date on which the planning permission referred to in subsection (2) is granted, and

(b) the date on which the relevant appeal or relevant petition, as the case may be, is determined,

shall not be due and payable.”,

and

(ii) by the deletion of subsections (3), (4) and (5),

(j) in section 653AFA(1)—

(i) in paragraph (a), by the substitution of “pursuant to section 34(12C) of the Act of 2000 or Chapter 3 of Part 4 of the Act of 2024” for “pursuant to section 34(12C) of the Act of 2000”,

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

“(b) an application for substitute consent, in accordance with section 177E of the Act of 2000, or retrospective consent, in accordance with Chapter 4 of Part 4 of the Act of 2024,”,

and

(iii) by the substitution of “(within the meaning of the Act of 2000 or, on and from the commencement of Part 4 of the Act of 2024, within the meaning of the Act of 2024)” for “(within the meaning of the Act of 2000)”,

(k) in section 653AFB—

(i) in subsection (2), by the substitution of “(within the meaning of the Act of 2000 or, on and from the commencement of Part 4 of the Act of 2024, within the meaning of the Act of 2024)” for “(within the meaning of the Act of 2000)”, and

(ii) in subsection (11)—

(I) in paragraph (a), by the substitution of “pursuant to section 34(12C) of the Act of 2000 or Chapter 3 of Part 4 of the Act of 2024” for “pursuant to section 34(12C) of the Act of 2000”, and

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

“(b) an application for substitute consent, in accordance with section 177E of the Act of 2000, or retrospective consent, in accordance with Chapter 4 of Part 4 of the Act of 2024,”,

(l) in section 653AG—

(i) in subsection (1)(a), by the substitution of “in accordance with section 10(2)(a) of the Act of 2000 or section 43(6) of the Act of 2024,” for “in accordance with section 10(2)(a) of the Act of 2000,”, and

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

“(7) (a) An owner of a relevant site to which this section applies shall make a declaration to the Revenue Commissioners, in such form and containing such information as they may prescribe, that this section applies to the relevant site—

(i) in a case in which a commencement notice is lodged subsequent to the site becoming a relevant site, within 30 days of the date on which the commencement notice, or the first such notice, as the case may be, referred to in subsection (2) is lodged, or

(ii) in all other cases, within 30 days of the site becoming a relevant site.

(b) The owner of a relevant site to which this section applies shall maintain and have available such records as may reasonably be required for the purposes of determining whether the requirements of this section are met.”,

(m) in section 653AGA—

(i) in subsection (3)—

(I) by the substitution of “Subject to subsections (3A), (4), (5) and (6),” for “Subject to subsections (4), (5) and (6),”,

(II) in paragraph (b), by the substitution of “part thereof.” for “part thereof,”, and

(III) by the deletion of “and residential zoned land tax so deferred shall be referred to in this section as ‘pre-development deferred residential zoned land tax’.”,

(ii) by the insertion of the following subsections after subsection (3):

“(3A) Where pre-development deferred residential zoned land tax would, but for this subsection, become due and payable in accordance with subsection (3)(a) on a date which occurs prior to the return date relating to the liability date referred to in subsection (3), such pre development deferred residential zoned land tax shall be due and payable on or before the return date.

(3B) Residential zoned land tax deferred in accordance with subsection (3) or (3A) shall be referred to in this section as ‘pre-development deferred residential zoned land tax’.”,

(iii) in paragraph (d) of subsection (4), by the substitution of “in accordance with subsection (3), (3A) or (6)” for “in accordance with subsection (3) or (6)”,

(iv) in subsection (6)—

(I) in paragraph (a), by the substitution of “in accordance with subsection (3) or (3A)” for “in accordance with subsection (3)”, and

(II) in paragraph (b), by the substitution of “subsections (3) and (3A) shall continue to apply” for “subsection (3) shall continue to apply”,

(v) in subsection (7), by the substitution of “in accordance with subsection (3), (3A) or (6)” for “in accordance with subsection (3) or (6)”, and

(vi) in subsection (8), by the substitution of “notwithstanding subsections (3) and (3A)” for “notwithstanding subsection (3)”,

(n) in section 653AH(3)(a), by the substitution of “within the meaning of the Act of 2024” for “within the meaning of the Act of 2000”, and

(o) in section 653AI—

(i) in subsection (5), by the substitution of “Notwithstanding sections 653Q and 653Z, and subject to subsections (5A), (6) and (7),” for “Notwithstanding section 653Q, and subject to subsections (6) and (7),”,

(ii) by the insertion of the following subsection after subsection (5):

“(5A) Subject to subsection (6), where the return date in respect of a liability date referred to in subsection (5) occurs after the earlier of the dates specified in paragraphs (a) and (b) of subsection (5), residential zoned land tax arising in respect of that liability date shall be payable on or before the return date in the year in respect of which the tax is charged.”,

(iii) in subsection (7), by the substitution of “section 653T” for “section 653U”,

(iv) by the substitution of the following subsection for subsection (10):

“(10) Where, on the date of death of a deceased person, section 653AF applies to a relevant site in respect of which the deceased person was the liable person immediately prior to their death, the personal representatives may, during the administration period, make a claim under section 653AF(2A) that the deceased person would have been entitled to make.”,

(v) in subsection (12)—

(I) by the substitution of “653AF(2A)” for “653AF(4) and (5)”, and

(II) by the substitution of “section 653AF(2A)” for “653AF(4) or (5)”,

and

(vi) in subsection (13) by the deletion of “653AF(4)(a)”.

104. Technical amendments to de minimis aid provisions

104. (1) The Principal Act is amended—

(a) in section 216F(7), by the deletion of paragraphs (b) and (d), and

(b) in section 667C(1), by the substitution of the following definition for the definition of “Commission Regulation (EU) No. 1408/2013”:

“ ‘Commission Regulation (EU) No. 1408/2013’ means Commission Regulation (EU) No. 1408/2013 of 18 December 2013[^60] as amended by Commission Regulation (EU) 2019/316 of 21 February 2019[^61], Commission Regulation (EU) 2022/2046 of 24 October 2022[^62], Commission Regulation (EU) 2023/2391 of 4 October 2023[^63] and Commission Regulation (EU) 2024/3118 of 10 December 2024[^64];”.

(2) Section 81D(1) of the Stamp Duties Consolidation Act 1999 is amended by the substitution of the following definition for the definition of “Commission Regulation (EU) No. 1408/2013”:

“ ‘Commission Regulation (EU) No. 1408/2013’ means Commission Regulation (EU) No. 1408/2013 of 18 December 2013[^65] as amended by Commission Regulation (EU) 2019/316 of 21 February 2019[^66], Commission Regulation (EU) 2022/2046 of 24 October 2022[^67], Commission Regulation (EU) 2023/2391 of 4 October 2023[^68] and Commission Regulation (EU) 2024/3118 of 10 December 2024[^69];”.

105. Miscellaneous technical amendments in relation to tax

105. The enactments specified in the Schedule—

(a) are amended to the extent and in the manner specified in paragraphs 1 to 5 of that Schedule, and

(b) apply and come into operation in accordance with paragraph 6 of that Schedule.

106. Care and management of taxes and duties

106. All taxes and duties imposed by this Act are placed under the care and management of the Revenue Commissioners.

107. Short title, construction and commencement

107. (1) This Act may be cited as the Finance Act 2025.

(2) Part 1 shall be construed together with—

(a) in so far as it relates to income tax, the Income Tax Acts,

(b) in so far as it relates to universal social charge, Part 18D of the Principal Act,

(c) in so far as it relates to corporation tax, the Corporation Tax Acts, and

(d) in so far as it relates to capital gains tax, the Capital Gains Tax Acts.

(3) Part 2, in so far as it relates to duties of excise, shall be construed together with the statutes which relate to those duties and to the management of those duties.

(4) Part 3 shall be construed together with the Value-Added Tax Acts.

(5) Part 4 shall be construed together with the Stamp Duties Consolidation Act 1999 and the enactments amending or extending that Act.

(6) Part 5 shall be construed together with the Capital Acquisitions Tax Consolidation Act 2003 and the enactments amending or extending that Act.

(7) Part 6 in so far as it relates to—

(a) income tax, shall be construed together with the Income Tax Acts,

(b) residential zoned land tax, shall be construed together with Part 22A of the Principal Act,

(c) corporation tax, shall be construed together with the Corporation Tax Acts,

(d) capital gains tax, shall be construed together with the Capital Gains Tax Acts,

(e) duties of excise, shall be construed together with the statutes which relate to duties of excise and the management of those duties,

(f) value-added tax, shall be construed together with the Value-Added Tax Acts,

(g) stamp duty, shall be construed together with the Stamp Duties Consolidation Act 1999 and the enactments amending or extending that Act, and

(h) gift tax or inheritance tax, shall be construed together with the Capital Acquisitions Tax Consolidation Act 2003 and the enactments amending or extending that Act.

(8) Except where otherwise expressly provided for in Part 1, that Part shall come into operation on 1 January 2026.

(9) Except where otherwise expressly provided for, where a provision of this Act is to come into operation on the making of an order by the Minister for Finance, that provision shall come into operation on such day or days as the Minister for Finance shall appoint either generally or with reference to any particular purpose or provision and different days may be so appointed for different purposes or different provisions.

SCHEDULE Miscellaneous Technical Amendments in Relation to Tax

Section 105

(a) in section 208(4)(a)

(i) by the substitution of “paragraphs (a) and (b) of subsection (2)” for “paragraphs (a) and (b) of subsection (1)”,

(ii) in subparagraph (i), by the substitution of “subsection (2)(a),” for “subsection (1)(a),”, and

(iii) in subparagraph (ii), by the substitution of “subsection (2)(b)” for “subsection (1)(b)”,

(b) in section 216A(8), by the substitution of “section 473C” for “section 244”,

(c) in section 1024(2)(a), by the deletion of subparagraph (xa), and

(d) in section 1031I(2)(a), by the deletion of subparagraph (xi).

(a) by the substitution of “subparagraph (2)(i)” for “subparagraph (2)(a)”, and

(b) by the substitution of “subparagraph (2)(ii)” for “subparagraph (2)(b)”.

(a) in section 94(1), by the substitution of the following definition for the definition of “greenhouse gas emissions permit”:

“ ‘greenhouse gas emissions permit’ means a permit granted under Regulation 7 of the European Communities (Greenhouse Gas Emissions Trading) Regulations 2024 (S.I. No. 470 of 2024);”,

and

(b) in section 104(1A), by the substitution of “Commission Implementing Decision (EU) 2022/197 of 17 January 2022[^70]” for “Commission Decision No. 2001/574/EC of 13 July 2001[^71]”.

(a) in section 66(1), by the substitution of the following definition for the definition of “greenhouse gas emissions permit”:

“ ‘greenhouse gas emissions permit’ means a permit granted under Regulation 7 of the European Communities (Greenhouse Gas Emissions Trading) Regulations 2024 (S.I. No. 470 of 2024);”,

and

(b) in section 77, by the substitution of the following definition for the definition of “greenhouse gas emissions permit”:

“ ‘greenhouse gas emissions permit’ means a permit granted under Regulation 7 of the European Communities (Greenhouse Gas Emissions Trading) Regulations 2024 (S.I. No. 470 of 2024);”.