Simon Harris (Wicklow, Fine Gael)

I move amendment No. 13:

In page 29, to delete lines 25 to 28 and substitute the following: “ “ ‘relevant state’ means, as regards the years of assessment 2012 to 2025, the Russian Federation, and as regards the years of assessment 2012 to 2030, the Federative Republic of Brazil, the Republic of India, the People’s Republic of China or the Republic of South Africa, and includes—”.

While taking this Bill on Report Stage having not taken it on Committee Stage, I want to acknowledge that this issue arose on Committee Stage. From my recollection, Deputies O'Callaghan and Nash and perhaps others highlighted this matter. I thank them for that. While there is a grouping of amendments, on this occasion we are all trying to achieve pretty much the same thing.

The foreign earnings deduction, FED, is an income tax relief available to employees who are tax resident in Ireland but who travel out of the State to temporarily carry out duties of their office or employment in certain qualifying countries. By incentivising employees to make overseas trips, the deduction aims to support Irish businesses seeking to develop and expand exports and business in new and emerging markets.

The Finance Bill 2025 provides for a number of amendments to the scheme, including a five-year extension to the end of 2030 and, in view of further encouraging market diversification, it also includes an increase to the maximum potential level of relief as well as its extension to the Philippines and Türkiye. As indicated on Committee Stage, officials engaged with the Department of Foreign Affairs and Trade and, following that Department’s analysis and recommendation, an amendment is now being brought forward to rightfully remove Russia as a relevant state for FED.

I would note that in 2023, the last year for which Revenue data is available, there were no claims for the deduction for business travel to or time spent working in Russia. The effect of this amendment will be that from 1 January 2026 it will not be possible to claim relief under the FED in respect of time spent working in Russia, bringing the relief into line with the wider Government and Irish policy in this area. As this Report Stage amendment is now being introduced, I will not accept the other amendments. We are all endeavouring to achieve roughly the same thing.

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