Ireland: Tax measures in Finance Bill 2024, including Pillar One Amount B rules, amendments to Pillar Two rules
Includes tax measures announced in 2025 budget
The Minister for Finance on October 10, 2024, introduced the Finance Bill 2024, which includes the tax measures included in the 2025 budget introduced on October 1, 2024 (read TaxNewsFlash), along with certain additional technical changes and simplifications to the tax code.
One particularly notable provision is the introduction of a new participation exemption for foreign sourced dividends from EU/EEA and tax treaty jurisdictions effective January 1, 2025.
In addition, the bill would introduce “Phase I” of the Pillar One Amount B rules into Irish law as of January 1, 2025, and amend the Pillar Two rules to incorporate parts of the OECD December 2023 administrative guidance and OECD June 2024 administrative guidance and to provide other clarifications.
The bill also includes the following tax-relief measures:
- Increase in the first-year payment threshold under the research and development (R&D) regime from €50,000 to €75,000
- Increase in the lifetime limit on capital gains tax (CGT) relief for angel investors from €3 million to €10 million
- Improvements in, and extensions to, the operation of the Employment Investment Incentive and other reliefs for investments in trading companies
- Improvement in CGT tax retirement relief which would, if certain conditions are met, allow for a full exemption from CGT for those under 70 who dispose of their businesses to their children
- Relief for expenses incurred on an initial stock market listing
Read an October 2024 report prepared by the KPMG member firm in Ireland, which covers:
- Business tax
- Individual (personal) tax
- Indirect tax
- Financial services tax
- Employment tax
- Property and construction
Read an October 2024 report prepared by KPMG’s EU Tax Centre