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Income Tax
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Capital Acquisitions Tax (CAT)
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Withholding Taxes (WHT)
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Verified Irish Tax Rules Reference (2025/2026)

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Income Tax

Income Tax Bands & Credits

Standard rate cut-off (€44k/€53k) and €2,000 personal/employee credits.

Residence & Domicile

Individual tax residency (183/280 days test), ordinary residence (3-year test), and remittance basis for non-doms.

EIIS Scheme

20%-50% tax relief on SME investments. 4-year hold.

SURE Scheme

Refund up to 41% of IT on starting/investing in own SME.

Stock Relief

25%, 50% or 100% farming stock value increase deduction.

Land Leasing Exemption

Tax-free lease income brackets up to €40,000 for 15+ years.

Incapacitated Child Credit

Section 465 tax credit of €3,800 per year for incapacitated child.

Dependent Relative Credit

Section 466 tax credit of €245 per year for maintaining relative.

Health Expenses Relief

20% standard rate relief on medical costs, 40% for nursing home.

Tuition Fees Relief

20% relief on third-level fees, max €7,000, standard disregard.

Rent-a-Room Relief

Exempt up to €14,000 rent in main residence.

Landlord Deductions

S.97/97A Case V deductions (pre-letting €10k, wear & tear, interest).

KEEP Scheme

Tax-efficient employee share options for SMEs.

Share Clogs Relief

Taxable value abatement (10%-60%) on restricted shares.

SARP

30% tax deduction for relocated salaries >€100k.

Section 825C SARP Relief

30% income tax exemption on qualifying salary above €100k.

Foreign Earnings Deduction

Up to €35,000 tax deduction for working in emerging markets.

Medical Expenses Relief

S.469 health relief at 20% standard rate (40% nursing home), no TRS, Med 2 cert.

Woodlands Occupation

S.232 commercial woodlands income and timber sale tax exemptions.

Sports & NGB Exemption

S.235/235A sporting body exemption & 10-year NGB project DIRT-free fund.

Gaeltacht Hosting

S.216B income tax exemption for Gaeltacht hosting under Scéim na bhFoghlaimeoirí.

Childminding Relief

S.216C childcare service relief exempts gross income up to €15,000 p.a.

Micro-Generation Exemption

S.216D income tax exemption up to €400 p.a. for domestic solar/wind power.

Instrument Production

S.216F tax exemption on manufacturing/repairing traditional Irish instruments.

Host Recognition Pay

S.216E host recognition payments (Ukrainian refugees) tax exemption.

DIRT Exemptions

S.256/267 DIRT exemptions (33% rate) for non-residents, charities, companies, and individuals 65+ under income limits (€18k/€36k).

Wear and Tear Allowances

S.284 machinery/plant capital allowances: 12.5% straight-line p.a. over 8 years, passenger car cap €24,000.

Emissions-Based Car Allowances

Section 374/380L car cost limits and write-downs based on CO2 emissions.

Accelerated Capital Allowances

100% capital allowance in year 1 for energy equipment.

Farm Safety Allowances

Section 285D accelerated capital allowances: 50% over 2 years.

Farm Buildings Allowances

Section 273 capital allowances: 15% over 7 years.

Individual Loss Relief

S.381 loss relief against general income, S.382 carry forward, and S.383 cessation relief.

Section 774 Occupational Pensions

Employer deductibility and employee relief capped by €115k earnings limit.

Section 784 Personal Pensions

Self-employed pension relief capped by €115k earnings limit.

Pension Relief

Age-related percentage relief capped by €115k earnings limit.

Corporation Tax

Section 481 Film Relief

32% tax credit on qualifying film expenditure capped at €125m.

Section 486C Start-up Exemption

5-year tax relief based on employer PRSI paid capped at €120k.

Knowledge Development Box

Reduced 10% effective tax rate on qualifying IP profits.

Section 486C Startup Relief

Up to €40k CT exemption per year for first 3 years of trade.

Section 481 Film Relief

Up to 32% tax credit for qualifying film/TV productions.

Group Loss Relief

Trading loss transfers within a 75% corporate group structure.

CGT Participation Exemption

100% CGT exemption on disposing >5% subsidiary shareholdings.

Woodlands Income Exemption

Section 232 tax exemption for commercial forestry profits.

Portfolio Dividends (12.5%)

S.21B 12.5% CT rate on foreign dividends from EU/DTA trading profits.

Dividend Exemption 2025

S.831B optional 100% CT exemption on foreign dividends from EU/DTA.

S.140 Woodlands & Stallion Dist

Tax exemption (and no tax credit) on distributions from exempt stallions, greyhounds, or woodlands profits.

S.141 Patent Royalty Dist

Income tax exemption on patent royalty distributions for eligible shares, capped at R&D spending. (Sunset: 24 Nov 2010).

S.142 Exempt Mine Dist

Exemption from income tax (and no tax credit) on distributions made out of exempted mining income.

S.143 Coal & Gypsum Dist

Reduced tax rate/liability (50% reduction) on distributions out of coal, gypsum, or anhydrite mining operations.

S.144 Shannon Airport Dist

Exemption from tax credit on distributions from Shannon Airport trading operations. Distributable income formula applies.

S.152 Dividend Warrants

Mandatory tax credit explanations/statements to accompany all dividend/interest warrants. Penalty of €200 per failure.

S.153 Non-Resident Dist

Income tax exemption/reduction on Irish-resident company distributions to EU, EEA, or treaty-resident persons/companies.

S.154 Period Attribution

Rules allowing companies to elect to attribute distributions to specified accounting periods (up to undistributed income).

S.155 Relief Restrictions

Restriction of tax credits/reliefs on distributions made out of exempt or relieved profits (stallions, forestry, mines, etc.).

S.156 Franked Investment

Definitions of Franked Investment Income (FII) and Franked Payments for company distributions and group loss relief.

Land Excepted Trades

S.21A land development trade taxed at 25% CT, physical construction at 12.5%.

Cost Rental Exemption

S.222A corporation tax exemption on cost rental dwellings rental profits.

Exempt Grants

S.223-226 employment and small/medium enterprise grant exemptions.

NCSB Exemption

S.227/Schedule 4 tax exemption on approved non-commercial state body income.

Local Authorities & Credit Unions

S.214/219A/220/228/229 local authority and credit union tax exemptions.

Friendly Societies & Trade Unions

S.211/213/215 friendly societies and trade unions income tax exemptions.

Section 110 SPV

Tax neutrality regime for securitisation & financial SPVs.

Pillar Two Minimum Tax

OECD global minimum tax rules (15%) and elections under Sections 111A to 111AAAE.

Interest Limitation Rule (ILR)

Section 817U: 30% EBITDA cap on net interest deductions with a €3 million de minimis limit.

Interest Relief (S.247)

S.247 loan interest charge relief for acquiring interest in trading/close companies.

Wear and Tear Allowances

S.284 machinery/plant capital allowances: 12.5% straight-line p.a. over 8 years, passenger car cap €24,000.

Emissions-Based Car Allowances

Section 374/380L car cost limits and write-downs based on CO2 emissions.

Industrial Buildings Allowance

S.268/272 industrial buildings allowance: 4% straight-line p.a. over 25 years on construction/refurbishment costs.

IP Capital Allowances

S.376 capital allowances on intangible assets/IP.

Accelerated Capital Allowances

100% capital allowance in year 1 for energy equipment.

Living City Initiative

100% refurbishment relief for pre-1915 properties in historic areas.

Farm Safety Allowances

Section 285D accelerated capital allowances: 50% over 2 years.

Farm Buildings Allowances

Section 273 capital allowances: 15% over 7 years.

Corporate Loss Relief

S.396 Case I carry forward/offset, S.396A relevant trading losses (12.5%), and S.396B value basis loss relief.

Section 400 Reconstructions

Trading loss and capital allowance carry forward on company reconstructions without ownership change.

Section 766 R&D Credit

30% tax credit on qualifying research and development activities.

R&D Tax Credit

30% tax credit on qualifying research and development spend.

Close Company Definitions

Definitions under Part 13 TCA 1997: Close company, participator, and associate.

Interest to Participators (S.437)

Section 437: Interest paid to participators restricted to 13% of nominal share capital or loan value.

Surcharge on Investment & Estate Income

Section 440: 20% surcharge on undistributed investment and estate income.

Surcharge Exemption & Distribution

Distribution windows (18 months) and the €2,000 de minimis surcharge threshold.

Surcharge on Professional Income

Section 441: 15% surcharge on undistributed professional service company income (50% base).

Loans to Participators (S.438)

20% grossed-up income tax charge on close company loans to participators or directors.

Expenses on Behalf of Participators

Section 436 deemed distributions: corporate expense benefits treated as dividends.

DWT & Withholding Taxes

Dividend Withholding Tax (DWT) at 25% on distributions and S.438 withholding refunds.

Capital Gains Tax (CGT)

Retirement Relief

CGT exemption on business/farm disposal. 2025 cap: €10m child.

Section 599 Retirement Relief

Retirement relief for family transfers with €10m cap (age 55-69) or €3m cap (age 70+).

Entrepreneur Relief

10% CGT rate on qualifying business assets. Limit €1m.

PPR Relief

100% CGT exemption on disposal of main residential home.

Section 604 PPR Exemption

Principal Private Residence CGT exemption on main residence disposal.

Section 626B Exemption

Corporate participation exemption from CGT on share disposals.

Farm Restructuring Relief

CGT exemption on land consolidation sales/purchases.

Site to Child Exemption

CGT exemption on transferring site up to €500k to child.

CGT Group Relief

No loss/no gain asset transfers within 75% corporate group.

CGT Reconstruction Relief

CGT deferral on commercial share swaps and reorganizations.

CGT Annual Exemption

First €1,270 of taxable gains per individual is exempt.

Incorporation Deferral

Section 600 CGT rollover when incorporating business going-concern.

Spouse CGT Transfer

Section 1028 no-gain/no-loss asset transfers between spouses.

Woodlands CGT Exemption

CGT exemption on disposal of growing commercial timber.

CGT Death Exemption

Exemption on death, base cost step-up to market value for heirs.

Share Buyback Relief

S.173-186 CGT treatment instead of income distribution treatment on company purchase of own shares, subject to tests.

Stock/Investment Transfer

S.596 market value deemed disposal and S.596(3) cost-basis deferral election.

Foreign Tax Credit

Schedule 24 double tax credit offset and foreign dividend credit pooling.

Capital Acquisitions Tax (CAT)

Agricultural Relief

90% CAT valuation reduction. Strict 2025 active farmer tests.

Business Relief

90% CAT reduction on business property. Must be trading.

Dwelling House Exemption

100% CAT exemption on main home. 3-year prior residency rules.

Small Gift Exemption

CAT exemption for first €3,000 of gifts received per donor in a year.

Foster Child Relief

Qualifies foster child for Group A tax-free threshold.

CAT Maintenance Exemption

Exemption for normal maintenance/education payments.

CAT Free Use of Money

Deemed gift tax benefit on interest-free loans.

Domicile & Residence (CAT)

Irish situs property always liable. Foreign property liable if donor or donee is resident (5-year rule for non-doms).

CAT Group Thresholds

Budget 2025 lifetime thresholds: Group A €400k, B €40k, C €20k.

Spousal CAT Exemption

100% CAT exemption on gifts/inheritances between spouses/civil partners.

CAT CGT Credit Offset

Credit CGT paid on lifetime transfer against CAT on same event.

Assurance Policies Relief

Section 72/73 CAT exemption on qualifying life assurance policy proceeds.

CAT Close Company Look-Through

Section 43 CATCA look-through rules attributing gifts/inheritances made to/by a close company directly to its participators.

Stamp Duty

Young Trained Farmer

100% stamp duty exemption. Under 35, qualified, €100k cap.

Consanguinity Relief

1% stamp rate on farmland transfers to related parties (to end 2028).

Stamp Site to Child

Exemption from stamp duty on site transfers under Section 83A.

Section 79 Associated Co.

Stamp duty exemption on transfers between 90% associated companies.

Section 80 Reconstruction

Stamp exemption on corporate reconstructions/undertaking transfers.

Residential Stamp Duty

New 2025 rates: 1% up to €1m, 2% to €1.5m, 6% on excess.

Bulk Buying Stamp Duty

15% rate on buying 10+ houses in a 12-month period.

Development Stamp Refund

Section 83D refund reducing stamp rate to 2% for residential dev.

Spousal Stamp Exemption

100% stamp duty exemption on property transfers between spouses.

Farm Consolidation Relief

1% reduced stamp duty on farmland consolidation transfers (to end 2028).

IP Stamp Exemption

100% stamp duty exemption on transfers/leases of intellectual property.

Value Added Tax (VAT)

VAT 58 Refund

Refund on farm building works & land reclamation for unregistered.

Flat Rate Addition

4.8% addition paid to unregistered farmers on produce sales.

VAT Input Credit

Standard recovery of VAT incurred on commercial business expenses.

VAT Transfer of Business

VAT-free treatment on going-concern business transfers (Section 20/26).

VAT Car Margin Scheme

VAT charged on profit margin of second-hand cars (Section 87).

VAT Property: New Properties

Section 94/111: VAT at 13.5% on sales of new properties and development land.

VAT Property: Joint Option (S.95)

Section 95: Joint election to tax an exempt sale, with purchaser reverse charge.

VAT Property: Capital Goods (CGS)

Chapter 2, Part 8: 20-year VAT input adjustment period and exempt sale clawbacks.

VAT Property: Transfer of Business

Section 20(2): VAT-free property transfer where CGS history is inherited.

VAT Cash Receipts Basis

Account for VAT when cash is received. Limit: €2 million turnover.

VAT Grouping

Register closely linked entities as a single VAT taxable person.

Section 56 Export Exemption

Zero-rating of inputs for qualifying exporters (>75% turnover exported).

VAT Capital Goods Scheme

Adjust input VAT on property acquisitions/fit-outs over 10-20 years.

VAT Travel Agents Scheme

Section 88 Tour Operators Margin Scheme (TAMS) 23% rate on margin.

Construction Reverse Charge

Principal accounts for VAT on construction services under RCT.

VAT Bad Debt Relief

Reclaim VAT paid on sales invoices that become bad debts after 6 months.

Trusts

Bare Trusts

Beneficiary retains beneficial interest and is taxed directly; trustee holds legal title with no active duties.

Fixed Trusts

Beneficiaries have a fixed, defined right to trust income or capital. Trustee has no discretion.

Discretionary Trusts

Trustee has discretion over distributions. Subject to 6% entry and 1% annual discretionary trust tax.

Non-Resident Trusts

Trustees reside and administer abroad. Section 579/579A CGT attribution & Section 806 income tax rules apply.

Irish Resident Trustees

Resident trust status for CGT/income if majority trustees resident, unless settlor is non-resident & non-domiciled.

Foreign Trusts (Irish Beneficiaries)

CAT on inheritances/gifts. Case III income taxation and Section 579 CGT on distributions to Irish residents.

Anti-Avoidance - Income & Corp Tax

General Anti-Avoidance (GAAR)

Section 811 General Anti-Avoidance Rules & 30% tax surcharges.

Transfer Assets Abroad

Section 806 taxing Irish residents on income routed to foreign entities.

Interest Limitation (ILR)

Section 817U interest deduction restriction to 30% EBITDA cap.

Mandatory Disclosure (DOTAS)

Section 817C/HB reporting of tax avoidance transactions within 30 days.

Close Co. Surcharge

Section 440 (20%) and Section 441 (15%) surcharges on undistributed investment/professional income.

Close Co. Loans

Section 438 grossed-up income tax charge on loans to participators.

Commerciality of Trades

Section 384 restricting loss offsets if not conducted on commercial terms.

Transactions in Securities

Section 817 cancellation of tax advantages from share transactions.

Anti-Avoidance - Capital Gains Tax (CGT)

Connected Persons MV

Section 547 deemed market value on connected-party asset transactions.

Clogged Losses (CGT)

Section 549 connected-party losses restricted to same-buyer gains.

Value Shifting (CGT)

Section 591 adjustments for shifting value out of shares before sale.

Non-Res Company Gains

Section 590 attributing gains of foreign close company to Irish shareholders.

Temporary Non-Residence

Section 29A taxing assets disposed of during temporary non-residence period.

Anti-Avoidance - Capital Acquisitions Tax (CAT)

Close Co. Look-Through

Section 43 look-through routing of CAT gifts/inheritances through close cos.

Deemed Gift on Free Loans

Section 40 taxing foregone interest on interest-free loans as a gift.

Discretionary Trust Tax

Section 11/20/21 trust taxes (6% entry charge & 1% annual tax).

Ag Relief Clawback

Section 89 clawback of agricultural relief if sold within 6 years.

Anti-Avoidance - Stamp Duty

Associated Co. Clawback

Stamp associated companies relief clawback if association ends in 2 years.

Stamp General Anti-Avoidance

Section 112 broad substance-over-form anti-avoidance rule.

Stamp Bulk Buying (15%)

Section 31E 15% stamp duty rate on bulk residential purchases.

Anti-Avoidance - Value Added Tax (VAT)

VAT TOB Limits

Section 20(2) denying VAT-free TOB relief if purchaser is unregistered.

VAT Abuse of Rights

Section 110/111 codifying Halifax principle for tax-avoiding structures.

VAT Group Joint Liability

Section 15 joint & several liability for VAT Group members.

Withholding Taxes (WHT)

PSWT (20% Professional Services)

Section 520 TCA 1997 withholding tax on professional services, Form F45, and interim refund claims.

RCT (0%/20%/35% Subcontractors)

Section 530 subcontractor compliance rates, principal notification, and reverse charge VAT.

Dividend Withholding (DWT)

S.172A-M exclusions from Dividend Withholding Tax for resident/non-resident qualifying persons, subject to Part 33 Chapter 5.

Interest Withholding (IWT)

S.246/246A interest withholding exemption for banks, clearing systems & EU/DTA.

Royalty Withholding (PRWT)

S.237/242A patent royalty withholding tax and EU/DTA trade exemptions.

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