I move:
"That the Bill be now read a Second Time."
We are here to begin our consideration of the Finance Bill, which will give the necessary legal basis to the decisions announced in the budget and make a number of other necessary updates to tax legislation. I will highlight some of the key measures contained in the Bill, but first it is useful to look at the context in which it is set.
On 1 October, I gave my first Budget Statement to this House, outlining the positive progress this Government has made since it took office in June 2020. I noted at the time that this progress was the direct result of the drive and focus we have to provide a better future for everyone, while also carefully managing our public finances. Budget 2025 puts in place the policies and measures to continue this positive trajectory and ensure that all our people see a promising and hopeful future in this country. Inflationary pressures have eased considerably over the past year and our domestic economy is operating at close to, if not at, full employment. In light of this, and particularly given the risks to our small, open economy from escalating international conflict and geopolitical instability, it was important that budget 2025 strikes the right balance between supporting individuals, families and businesses, and investing in our public services and infrastructure to prepare for future challenges.
The Minister for Public Expenditure, National Development Plan Delivery and Reform, Deputy Donohoe, and I, announced a total budget package of €10.5 billion consisting of a core expenditure package of €6.9 billion, a tax package of €1.4 billion and a one-off cost-of-living package of €2.2 billion. The budget addressed the major issues facing Ireland, including infrastructure and investment, and climate challenges, and underlined this Government’s commitment to support households, families, individuals and businesses to deal with current challenges and to look to the future with optimism. I look forward to further consideration of the detail of this important Bill as it progresses through the Oireachtas over the coming weeks. However, today I will provide an overview of some of the key measures and sections in the Bill in more detail but I will not have time to cover them all.
The focus of the personal income tax package in budget 2025 is to support low- and middle-income earners by building on the progress made during this Government’s term, specifically on tax credits and the universal social charge, USC, reductions. This is the fourth consecutive year that the Government has been in a position to provide a substantial income tax package. The €1.6 billion personal income tax package for 2025 includes raising the personal, employee PAYE and earned income tax credits by €125 each to €2,000. The standard rate cut-off point for income tax also increases by €2,000, to €44,000 for a single person, with commensurate increases in the bands applying to married persons and people in civil partnerships. In addition, the Bill reduces the 4% rate of USC applicable to incomes between €27,383 and €70,044 per annum to 3%. These changes will benefit everyone who pays income tax. Further, to take account of the national minimum wage increase that will apply from 1 January 2025, the 2% rate band ceiling for the USC will increase to €27,382. This will ensure that the 2% rate remains the highest rate of USC that is charged on the income of full-time minimum wage workers.
The Bill also provides for an increase to the home carer tax credit to €1,950 in line with the programme for Government commitment to support stay-at-home parents. Additionally, the single person child carer credit increases to €1,900, the incapacitated child tax credit increases to €3,800, the dependent relative tax credit increases to €305 and the blind person tax credit increases to €1,950. These changes are set out in sections 2 and 3.
Innovative, start-up and scaling businesses are of vital importance in our economy and provide significant employment nationwide. Accordingly, I am bringing a number of amendments to existing measures as well as introducing some new tax measures to help businesses to thrive and to grow. The amendments include changes to the employment investment incentive, EII, the start-up relief for entrepreneurs, SURE, the start-up company relief, the angel investor relief and the research and development tax credit.
With regard to new measures, section 50 introduces a participation exemption for foreign dividends. This measure will provide an exemption from corporation tax for qualifying dividend payments, subject to certain rules, and delivers on a commitment set out in the roadmap that was published by my Department last year. It is expected to significantly lower the administrative burden faced by taxpayers when paying dividends back to Ireland. I am also introducing a new relief for expenses incurred in connection with a first listing on an Irish or European stock exchange.
As I noted in my Budget Statement, farmers play an important role in our economy and are well regarded for their quality produce and farming methods. The Bill contains a number of measures to support farmers including the extension of the general, young trained farmer and registered farm partnerships stock reliefs for a further three years to the end of 2027. The Bill also provides for further qualifying equipment types to be added to the farm safety equipment eligible for the accelerated capital allowance scheme for farm safety equipment. The capital acquisitions tax agricultural relief promotes the transfer of farms from one generation to the next and is an important measure to allow our young people to pursue careers on the family farm. The Bill introduces a six-year active farmer requirement prior to the date of the gift or inheritance for the person who provides the gift or inheritance. This measure was developed in response to the concerns raised by farming representative bodies and to ensure that there are no cliff-edge impacts the legislation allows for a six-year transitional period for implementation.
The Government has invested unprecedented levels in housing delivery and it is our priority to continue to accelerate the supply of residential accommodation. To provide certainty to prospective homebuyers and the market, section 7 extends the help-to-buy scheme by a further four years to the end of 2029, and also provides for an amendment to the scheme in respect of its interaction with the local authority affordable purchase scheme to ensure that approved affordable purchasers will not lose out on an affordable property or their eligibility for the help-to-buy scheme due to timing delays.
Other measures included in the Bill to address the challenges in the housing market include an increase to the rental tax credit both for 2024 and 2025, an extension of the mortgage interest tax relief, the extension of the pre-letting expenses regime to assist landlords in preparing properties for the rental market, an increase in the rate of vacant homes tax and changes to the residential zoned land tax. The Bill also confirms the budget night resolutions introduced to give effect to a new rate of stamp duty on higher value residential properties and an increase in the rate applying to bulk purchase of homes.
The Bill includes a number of climate-related tax measures to incentivise the purchase of low-emission vehicles and retrofitting. For instance, the Bill provides for downward adjustments to the maximum emission thresholds for claiming capital allowances on company cars. These will be reduced from 155 g/km to 140 g/km with effect from 1 January 2027, allowing sufficient advance notice for the sector. It is hoped that this measure should, over time, incentivise the purchase of electric vehicles and help to create a more vibrant second hand electric vehicle market. Further supports to help transition to electric vehicles in commercial fleets include a new exemption from benefit-in-kind for the installation of a home charging facility in respect of employer-provided electric vehicles. Currently, due to their battery weight, battery electric vehicles are at a competitive disadvantage compared to their fossil fuel counterparts, as they cannot qualify for the reduced €200 rate of vehicle registration tax, VRT. However, the Bill amends the weight ratio for commercial battery electric vehicles to enable them to qualify for this lower rate.
I am also introducing an emissions-based approach to VRT for category B vehicles. Currently they are charged at 13.3% of the vehicle’s open market selling price. However, with effect from 1 July 2025, there will be a lower, 8% rate for category B vehicles with CO2 emissions of less than 120 g/km.
To reduce the cost where heat pumps are an integral part of retrofits, the Bill provides for a reduction in the VAT rate for heat pumps to 9% with effect from 1 January 2025.
Turning to the contents of the Bill itself, the first sections deal with income tax changes that I have outlined. To support the recruitment and retention of staff in the Naval Service, section 4 extends the seagoing naval personnel tax credit for five years to 2029.
Section 5 provides for changes to the rental tax credit. In recognition of the cost-of-living pressures facing many renters right now, an additional €250 will be claimable in respect of the credit for 2024. This will bring the value of the credit to €1,000 or €2,000 for single or jointly assessed persons, respectively, and can be claimed from January 2025 onwards. In addition, for 2025 the credit will increase from €750 to €1,000 or, in the case of jointly assessed taxpayer units, from €1,500 to €2,000.
Last year’s Finance Act introduced a new mortgage interest tax relief for mortgage holders who experienced increased interest rates in 2023 over 2022. Section 6 extends this relief for one further year. As such, the relief will also be available in respect of the increase in interest paid on a qualifying mortgage in the calendar year 2024 compared to 2022.
Section 7 extends the help-to-buy scheme as highlighted earlier.
Section 8 amends the small benefit exemption, which provides an exemption from income tax, PRSI and USC where an employer provides non-cash benefits to an employee in a year of assessment. The number of benefits will be increased from two to five in a year and the maximum cumulative value of incentives that can be provided to an employee in a year will be increased from €1,000 to €1,500. This will provide employers with greater flexibility to tailor their non-cash employee rewards systems.
Section 9 introduces a new exemption from benefit-in-kind for the installation of a home charging facility in respect of employer-provided electric vehicles.
Sections 10 and 11 extend the reduction of €10,000 applied to the original market value of a vehicle in category A to D vehicles and the amendment to the lower limit of the highest mileage band for the purpose of determining the benefit-in-kind payable.
Section 14 provides for the tax treatment of the auto-enrolment retirement savings scheme to be commenced when the scheme begins operation. The tax treatment is generally in line with that available for personal retirement savings accounts, PRSAs but participants in the automatic enrolment scheme will receive a State top-up payment rather than tax relief on their contributions.
Sections 16 and 17 provide for a number of enhancements to the current tax arrangements for charities. Currently, eligibility for tax relief on donations under the charitable donation scheme is only available after the charity has been registered for two years.
The Bill removes the waiting period so that approved bodies can obtain the tax relief immediately. To further support charities and their work and the wider implementation of the national philanthropy policy, the Bill will also allow charities five years to apply tax-relieved funds to their charitable purpose rather than the current two-year period operated on an administrative practice.
Sections 19, 20 and 21 provide for a range of measures to support national governing bodies, NGBs, for sports in investing for long-term projects. To further incentivise donations to sports bodies, the Bill will allow donors to sports bodies to decide whether they keep the tax benefit for themselves or elect to give the relief to the sports body. Furthermore, certain approved NGBs will be allowed an exemption from tax for funds it invests for a period of up to ten years. The exemption will apply so long as the income is ultimately applied for specified qualifying purposes, which include capital projects, the promotion of participation in sports by women and people with disabilities, the purchase of certain sports equipment and supporting high-performance athletes.
Sections 30 and 31 provide for exemptions from tax in respect of payments made under the CervicalCheck and Stardust ex gratia payment schemes, respectively. Section 32 extends the accelerated capital allowances scheme for gas and hydrogen vehicles and refuelling equipment for a further year. Section 33 amends the capital allowances regime for expenditure on cars which I mentioned earlier. Section 37 extends the employment investment incentive, the start-up capital incentive and the start-up relief for entrepreneurs until the end of 2026. It also doubles the limit on the amount of an investment on which an investor can claim relief under the employment investment incentive from €500,000 to €1 million, and increases the maximum qualifying investment in respect of which an investor may claim relief under the start-up relief for entrepreneurs over the seven-year period to €980,000, which is €140,000 per annum. Building on the significant enhancements made to the research and development tax credit in the previous two budgets, section 41 provides for an increase in the amount of the claim payable in the first year from €50,000 to €75,000. Section 45 provides for amendments to the transfer pricing provisions of the Taxes Consolidation Act 1997 and provides for the political commitment in respect of amount B or pillar 1 of the OECD two--pillar solution to address tax challenges arising from the digitalisation of the economy.
Section 48 provides for a new uplift for small to medium-size feature film productions under the section 481 film relief. The Scéal uplift will be granted at an additional rate of 8% for film productions with a maximum qualifying expenditure of €20 million. This will provide for a total support of 40% for in-scope productions. This measure is subject to EU state aid approval. As I announced on budget day, and also subject to approval by the EU, section 49 introduces a new tax credit to support the unscripted production sector. The relief will incentivise the making of unscripted productions by providing a refundable corporation tax credit at a rate of 20% on eligible expenditure of between €250,000 and €15 million per project. Where a producer is making multiple seasons of a TV show or making a show for multiple jurisdictions, they can claim the credit in respect of one season per 12-month period. The introduction of this credit, allied to synergies with our established film and animation sectors, will support the continued growth of our audiovisual sector.
Sections 53 and 54 provide for the angel investor relief introduced in budget 2024 and provide a reduced rate of capital gains tax, CGT, for investors in innovative start-ups when they dispose of a qualifying investment. The measure is expected to commence shortly. To further promote Ireland’s angel investment environment, the Bill provides that the lifetime limit on gains to which the reduced rate of CGT applies will be increased from €3 million to €10 million. Section 55 retains the increase of the upper age limit for CGT retirement relief which was introduced in the Finance (No. 2) Act 2023. The section also provides that, should the child retain ownership of the asset, the CGT will be abated. However, where there are disposals above €10 million by the child or children within 12 years of receiving the assets, a clawback of the relief will apply. This is intended to encourage retention of the assets over a longer term to support the growth and scaling of family-owned businesses.
Sections 57 to 68 and Schedule 1 introduce a domestic tax on e-cigarettes. The tax will apply at a rate of 50 cent per millilitre of e-liquid. Due to the operational and administrative challenges associated with this measure, it will require commencement in the middle of next year and therefore will be subject to a commencement order. Section 70 confirms the budget night increase of €1 on a pack of 20 cigarettes, with a pro rata increase on other tobacco products. A series of enhancements to the Finance Act 2002 are set out in section 71 to ensure that the Gambling Regulation Bill 2022, which is currently progressing through the Houses, can operate effectively when enacted.
Section 79 extends the 9% rate of VAT for gas and electricity to the end of April next year. Section 83 amends the flat-rate VAT scheme for unregistered farmers from the current 4.8% to 5.1% with effect from 1 January 2025. This annual adjustment is made on the basis of macroeconomic data received from the Central Statistics Office and the Revenue Commissioners. Section 90 provides for changes to the rates of stamp duty applying on the acquisition of residential property. As approved by the House on budget night, the higher rate of stamp duty on bulk acquisitions of houses is increased from 10% to 15%. The rate of stamp duty applicable to residential property valued above €1.5 million is increased to 6%. The existing rate of 1% will continue to apply to values up to €1 million and 2% on values above €1 million, with a third rate of 6% to apply to any value in excess of €1.5 million. Normal transitional arrangements will apply, as I said previously.
Section 92 provides for amendments to both the young trained farmer stamp duty relief and the stamp duty relief applying to farmers who lease land. The relief for young trained farmers will be available where it is claimed by an individual farmer who carries on the farm business through a company. The leasing relief will also encompass farmers who have chosen to incorporate their business. This reflects modern developments in the agriculture sector.
Section 96 applies the revised bank levy introduced last year on the same basis in 2025. It applies to banks which received financial assistance from the State, namely, Bank of Ireland, AIB, EBS and PTSB. Section 99 increases the three capital acquisitions tax tax-free thresholds which apply to gifts or inheritances as follows: group A, from a parent to a child, from €335,000 to €400,000; group B, from a brother, sister, aunt, uncle, etc., from €32,500 to €40,000; and group C, which applies in all other cases, from €16,250 to €20,000.
In the miscellaneous provisions section of the Bill, sections 105 to 110, inclusive, give effect to the announcement earlier this year of the reduction in the interest rate applying to debts in the tax debt warehousing scheme introduced during the pandemic from 3% to 0% where taxpayers engaged with the Collector General before 1 May 2024. Section 113 provides for an increase in the rate of the vacant homes tax from five to seven times the property’s existing base local property tax liability. The increase will take effect from the next chargeable period, commencing this November. Residential zoned land tax will be payable in 2025 in an effort to ensure that zoned, serviced land which is ready to deliver housing is activated and to encourage the process of seeking, gaining and activating planning permissions. Among other amendments to the tax, section 114 introduces provisions intended to ensure that the measure does not unduly impact landowners undertaking genuine economic activity on this land, for example, those engaged in farming. For such landowners applying for rezoning in 2025, the residential zoned land tax liability will not arise. These rezoning requests will be supported through section 28 guidance issued to local authorities from the Minister for housing. Sections 116 to 117 deal with the technical amendments and care and management sections.
I appreciate that time did not allow me to speak to every section of the Bill, as I am out of time now. Further detail is set out in the explanatory memorandum published alongside the Bill. As is customary with the Finance Bill, there are still a number of small matters under consideration which I may bring forward as amendments during future legislative Stages. The Bill sets out the legislative provisions to give effect to the tax measures announced in the budget. It demonstrates the Government's commitment to helping individuals and families and to ensuring that indigenous businesses can grow and prosper and that Ireland remains a highly attractive and competitive place for international investment and business. I look forward to working with everyone in the House as we bring forward this important legislation in the coming weeks.