Dáil debates

Tuesday, 4 November 2025

Finance Bill 2025: Financial Resolutions

 

3:55 am

Photo of Paschal DonohoePaschal Donohoe (Dublin Central, Fine Gael)
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I move:

1. THAT section 531AM of the Taxes Consolidation Act 1997 (No. 39 of 1997), which contains the main charging provisions for Universal Social Charge (USC), be amended in the manner and to the extent specified in the Act giving effect to this Resolution, to include a reference to Section 847AA which provides for a scheme of tax relief for donations to certain National Governing Bodies (NGB) where the donations are used to fund certain projects. The amendment provides that a donation to an NGB is not deducted when calculating an individual’s USC liability. This follows similar treatment for donations under section 847A TCA (donations to certain sports bodies) and section 848A TCA (donations to approved bodies), whereby such donations are exempt from Income Tax but are not exempt from USC.

2. THAT section 14 of the Finance Bill, which relates to section 14 of the Finance Act 2024 through which the taxation measures for the Automatic Enrolment Retirement Savings System into the Taxes Consolidation Act 1997 (No. 39 of 1997) were inserted, is repealed, in the manner and to the extent specified in the Act giving effect to this Resolution.

3. THAT Part 30 of the Taxes Consolidation Act 1997 (No. 39 of 1997), which relates to Occupational Pension Schemes, Retirement Annuities, Purchased Life Annuities and Certain Pensions be amended to provide for the tax treatment of the Automatic Enrolment Retirement Savings System, including the taxation of payments from the scheme, in the manner and to the extent specified in the Act giving effect to this Resolution.

4. THAT section 16 of the Finance Bill, which relates to section 15 of the Finance Act 2024, through which a number of necessary auxiliary amendments consequential to the insertion of Chapter 2E into the Taxes Consolidation Act 1997 (No. 39 of 1997) were inserted, is repealed, in the manner and to the extent specified in the Act giving effect to this Resolution.

5. THAT the Taxes Consolidation Act 1997 (No. 39 of 1997) be amended by the insertion of a new Section 1009A to provide that foreign body corporates which are substantially similar to partnerships formed under the law of the State and their members shall be chargeable to tax in the manner and to the extent specified in the Act giving effect to this Resolution.

6. THAT section 731 of the Taxes Consolidation Act 1997 (No. 39 of 1997), which provides for tax exemptions for a unit trust which neither is, nor is deemed to be, an authorised unit trust scheme, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

7. THAT section 291A of the Taxes Consolidation Act 1997 (No. 39 of 1997), which provides relief from corporation tax for capital expenditure incurred on specified intangible assets, be amended in the manner and to the extent specified in the Act giving rise to this Resolution.

8. THAT section 400 of the Taxes Consolidation Act 1997 (No. 39 of 1997), which contains provisions for the corporation tax treatment of certain company reconstructions, be amended in the manner and to the extent specified in the Act giving rise to this Resolution.

9. THAT Section 481A of the Taxes Consolidation Act 1997 (No. 39 of 1997), which contains provisions in relation to relief for investment in digital games, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

10. THAT section 891H of the Taxes Consolidation Act 1997 (No. 39 of 1997), which contains provisions in relation to country-by-country reporting, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

11. THAT section 71 of Finance Act 2010, which provides for relief from natural gas carbon tax on natural gas used for certain purposes, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

12. THAT section 82 of Finance Act 2010, which provides for relief from solid fuel carbon tax on solid fuels used for certain purposes, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

13. THAT section 6 of the Value-Added Tax Consolidation Act 2010 (No. 31 of 2010) which relates to persons not accountable persons unless they so elect be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

14. THAT Schedule 3 to the Value-Added Tax Consolidation Act 2010 (No. 31 of 2010), which relates to goods and services chargeable at the reduced rate of value-added tax, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

15. THAT Section 96 to the Value-Added Tax Consolidation Act 2010 (No. 31 of 2010), which relates to waiver of exemption under old rules, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

16. THAT Part 7 of the Stamp Duties Consolidation Act 1999 (No. 31 of 1999), which provides for exemptions and reliefs from Stamp Duty to apply in certain circumstances, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

17. THAT section 126AB of the Stamp Duties Consolidation Act 1999 (No. 31 of 1999) be amended in the manner and to the extent specified in the Act giving effect to this Resolution to provide for a stamp duty to be levied on certain financial institutions.

18. THAT section 125A of the Stamp Duties Consolidation Act 1999 (No. 31 of 1999), which provides for a stamp duty to be levied on health insurance contracts that are entered into or renewed between authorised insurers and their customers in each quarter, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

19. THAT section 41 of the Capital Acquisitions Tax Consolidation Act 2003 (No. 1 of 2003), which contains provisions relating to gifts and inheritances of life assurance policies, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

20. THAT the Taxes Consolidation Act 1997 (No. 39 of 1997) be amended by the amendment of section 811C(4)(a) to provide that a tax advantage arising from a tax avoidance transaction can be withdrawn in the manner and to the extent specified in the Act giving effect to this Resolution.

21. THAT the provisions contained in Part 4A of the Taxes Consolidation Act 1997 (No. 39 of 1997), which provides for the implementation of Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

22. THAT the provisions contained in section 638A of the Taxes Consolidation Act 1997 (No. 39 of 1997), which provides for the liabilities and obligations of, and the requirement of things to be done by, a successor company in relation to a merger or division pursuant to the Companies Act 2014, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

23. THAT section 959AA of the Taxes Consolidation Act 1997 (No. 39 of 1997), which relates to time limits on assessments made or amended by a Revenue officer on chargeable persons, be amended in the manner and to the extent specified in the Act giving effect to this resolution, to provide that a Revenue officer may make or amend an assessment on a chargeable person outside the normal four-year period to give effect to a Mutual Agreement Procedure reached under a limited scope treaty which is given the force of law by virtue of section 826(1B) of the Taxes Consolidation Act 1997.

24. THAT Section 959AU of the Taxes Consolidation Act 1997 (No. 39 of 1997), which deals with the date of payment of tax for amended assessments, be amended in the manner and to the extent specified in the Act giving effect to this resolution, to clarify that where an assessment is amended more than once, the date for payment of tax arising from a second or subsequent amended assessment is determined in isolation from the due date for tax arising from the first amended assessment.

25. THAT the provisions contained in section 840A of the Taxes Consolidation Act 1997 (No. 39 of 1997), which provides for a restriction on the deductibility of interest on loans for certain purposes, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

26. THAT section 100 of the Finance Act 1999, which provides for mineral oil tax reliefs for certain fuels, and qualifying uses, be amended in the manner and to the extent specified in the Act giving effect to this Resolution.

Question put and agreed to.