Business Taxes

Finance Bill 2025, Increased Revenue Powers, Income Tax and Corporation Tax

The Minister for Finance, Paschal Donohoe, published Finance Bill 2025 today, 16th October 2025, giving effect to the tax measures announced in Budget 2026 of last week.

Section 31 of the Bill introduces a new Section 959AX TCA 1997 to Part 41A TCA 1997. This legislation gives the Revenue Commissioners the authority to estimate corporate and income tax liabilities and serve notice in writing specifying the estimated tax due in circumstances where the taxpayer fails to file the required Tax Return within the specified return date. This estimated figure will be based on the higher of (i) the average amount of tax due on the two most recent tax returns, or (ii) €1,000.

Section 90 of the Bill amends the wording in Section 811C (4)(a) TCA 1997, which strengthens Revenue’s powers to counteract tax avoidance by expanding the scope of the legislation.  This amendment extends and enhances the Revenue Commissioners’ authority to withdraw or deny, at any time, tax advantages arising from tax avoidance transactions.  It specifically pertains to situations where an individual either takes or fails to take any other action, which directly or indirectly, seeks to obtain a tax advantage as a result of a tax avoidance transaction.

Section 93 of the Bill amends Section 638A TCA 1997.  This extends the transfer of rights and obligations under company mergers or divisions to include those arising under Part 4A TCA 1997. It provides that the Pillar Two compliance obligations, including tax payments and filings, will transfer to the successor company or companies, under a merger or division.

Section 879 TCA 1997 provides that the Revenue Commissioners may issue a notification to a taxpayer requesting that individual to deliver a tax return, in any tax year. Section 94 of the Bill amends Section 869 TCA 1997 allowing Revenue to issue such Income Tax Return Notices electronically i.e. via MyAccount or ROS.

Section 95 of the bill amends Section 959AA of the TCA 1997.  This amendment expands the Revenue Commissioners’ power to make or revise a tax assessment outside the standard four year time limit, so as to give effect to a Mutual Agreement Procedure outcome under a Tax Information Exchange Agreement, by virtue of section 826(1B) TCA 1997. Currently, under existing rules, a Revenue officer is allowed to make such an extended assessment in circumstances where a MAP is reached under a double taxation agreement.

Section 98 amends Section 959I TCA 1997 by inserting a new subsection 6 to clarify that a “chargeable person” may still make a claim for an allowance, deduction or relief even where that tax return is filed after the specified deadline date, unless, another provision in the Taxes Acts explicitly prevents the making of such a late claim.

For further information, please click: https://www.gov.ie/en/department-of-finance/press-releases/minister-donohoe-publishes-finance-bill-2025/

If you have received a notification of a level 1 or 2 Revenue Compliance Intervention or a level 3 Investigation into your or your company’s tax affairs, please contact us.  We also carry out tax health checks for companies and individuals to assist in identifying potential areas of exposure.For a full professional taxation advice and compliance service, please contact us at queries@accountsadvicecentre.ie

Please be aware that the information contained in this article is of a general nature.  It is not intended to address specific circumstances in relation to any individual or entity. All reasonable efforts have been made by Accounts Advice Centre to provide accurate and up-to-date information, however, there can be no guarantee that such information is accurate on the date it is received or that it will continue to remain so. This information should not be acted upon without full and comprehensive, specialist professional tax advice.

Payroll Taxes. Employee and Employer Taxes. Pension Auto-enrolment. Benefit-in-Kind (BIK)

Budget 2026 was announced on Tuesday, 7^th October 2025.  From 1^st January 2026, the National Minimum Wage for people aged twenty and over will increase, by 65 cents, to €14.15 per hour.  Other changes for employees and employers include the following:

Small Benefit Exemption

• The Small Benefits Exemption enables employers to provide tax-free benefits of up to €1,500, per employee, per year.  The benefit must be in the form of a voucher which can only be redeemed in exchange for goods and services.  In other words, this exemption from PAYE, USC and PRSI only applies to benefits that cannot be exchanged for cash, such as gift vouchers or store cards.

• Please be aware that the Small Benefit Exemption cannot be combined with salary sacrifice arrangements.

For further information, please click: https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-05/05-01-01e.pdf

PRSI Changes

• Employee and Employer PRSI rates will increase by a further 0.15% on 1st October 2026.

• From 1^st October 2026, the employee PRSI rate will increase to 4.35%.

• The employer PRSI rate will increase to 9.15% where weekly income is €552 or less.

• For weekly salaries/wages in excess of €552, employer’s PRSI will increase to 11.40%.

For further information, please click: https://assets.gov.ie/static/documents/cb168977/PRSI_C20260116_Contribution_Rates_and_User_Guide_-_SW_14_-_English_Version_-_January_2026_.pdf-web.pdf

USC changes

From 1st January 2026, the 2% Universal Social Charge threshold will increase to €28,700.  This is in line with the increase in the national minimum wage. Therefore, If you earn €28,700 or under, your USC rate remains at 2%.

The amount of income liable to the 3%USC rate reduces from €42,662 to €41,344.

The 2% USC rate will continue to apply until 31st December 2027 for individuals holding a full medical card and whose total income for the year is €60,000 or less.

For further information, please click: https://www.revenue.ie/en/jobs-and-pensions/usc/standard-rates-thresholds.aspx

Benefit-in-Kind

• The universal reduction of €10,000 to the Original Market Value of company cars in categories A-D as well as to all vans, will remain for 2026, then reduce to €5,000 in 2027, €2,500 in 2028 and won’t apply in 2029.

• From 1^st January 2026 a new vehicle category (A1) is being created for zero-emission cars. BIK on category A1 cars will be calculated at between 6% and 15% of the cars OMV, subject to business mileage.

• From 1^st January 2026, the highest mileage band for the Benefit-in-Kind calculation will be reduced to 48,001 km.

For further information, please click: https://www.revenue.ie/en/corporate/press-office/budget-information/current-year/budget-summary.pdf

Auto-enrolment

From 1^st January 2026, the Pension Auto-enrolment scheme will start.

The National Automatic Enrolment Retirement Savings Authority automatically will determine eligibility based on Revenue payroll data.  Briefly:

• Employees aged between 23 and 60 years, who earn in excess of €20,000 per year and who are not already part of a workplace pension scheme (with payroll contributions) will be automatically enrolled into this system.

• Employees earning under €20,000 per year can opt in voluntarily.

• Currently self-employed individuals are not eligible for this scheme.

• From 1^st January 2026, employees and employers will each pay 1.5% of the gross salary into the scheme. This will be the case for three years.  After that the contributions will go up to 3% (in years 4 to 6), then 4.5% (in years 7 to 9) and then 6% from year 10.

• In addition to the employee and employer contributions, the government will top up the employee’s contribution. From 1^st January 2026, for every €3 an employee contributes, the employer will also pay in €3 with the State then topping it up by €1.  In other words, the government will top up the employee’s contribution by 1/3^rd.

• Employees can only opt out after six months of enrolment. If they decide to opt out their employee contributions are refunded. Employer and state contributions, however, will remain in their pension fund.

• Automatic re-enrolment into the scheme will occur after two years provided the eligibility criteria still apply.

For further information, please click: https://myfuturefund.ie/

Accounts Advice Centre Employment tax services work with our valued clients to ensure that all payroll compliance obligations are met in the most timely and cost effective manner possible.  We specialise in payroll, employee tax services and director tax services.  For further information please contact us at queries@accountsadvicecentre.ie

Please be aware that the information contained in this article is of a general nature.  It is not intended to address specific circumstances in relation to any individual or entity. All reasonable efforts have been made by Accounts Advice Centre to provide accurate and up-to-date information, however, there can be no guarantee that such information is accurate on the date it is received or that it will continue to remain so. This information should not be acted upon without full and comprehensive, specialist professional tax advice.

Research and Development, R&D Tax Credit, Corporation Tax. Revenue Audits

The Research and Development Tax Credit provides a 30% tax credit for all qualifying R&D expenditure.  It increased from 25% to 30% for accounting periods commencing on or after 1^st January 2024.  There is expected to be a further increase in Budget 2026.  It’s important to keep in mind that this tax credit is available in addition to the corporation tax deduction available for expenditure incurred on R&D.  Therefore, this can result in an effective tax saving of 42½%; being a 12½% corporation tax deduction plus a 30% R&D tax credit.

So, what is Research and Development (R&D)?

The Revenue Commissioners have outlined criteria, in their guidelines, to enable companies determine whether their activities qualify for the tax credit.

According to Revenue’s most recent guidance material, “to qualify for the R&D Tax Credit, a company’s R&D activities must:

1. involve systematic, investigative or experimental activities

2. be in the field of science or technology

3. involve one, or more, of the following categories of R&D:

• basic research
• applied research
• experimental development

4. seek to make scientific or technological advancement and

5. involve the resolution of scientific or technological uncertainty.”

For further information please click https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-29/29-02-03.pdf

Qualifying R&D expenditure includes:

• qualifying operational R&D costs and

• qualifying R&D plant and equipment costs

• There is also a separate R&D tax credit in relation to buildings and structures.

Recent Amendments

• On 13^th January 2025, Revenue updated their guidance material. Section 766C TCA 1997 was amended to increase the first instalment threshold amount from €50,000 to €75,000, in relation to accounting periods commencing on/after 1^st January 2025.

• On 7^th July 2025, Revenue released a four part video, providing guidance on how to complete the R&D panels in the 2024 CT1 Form.

R&D Video Guidance

Did you know that the Revenue Commissioners have released a four part guideline video on the completion of the Research & Development (R&D) panels on the Form CT1 2024?

The videos focus on:

1. Part 1 shows you how to correctly complete the sections for grants and subcontractor costs.

2. Part 2 shows you how to complete the relevant panels on the Form CT1 in relation to instalments from 2022 and 2023. It also covers how to claim for carried forward amounts under section 766(4B) TCA 1997.

3. Part 3 shows you how to make claims under section 766C TCA 1997.

4. Part 4 shows you how to claim group relief. It also outlines some of the common errors in the R&D panels that may arise when completing the 2024 Form CT1.

Please click link: https://www.revenue.ie/en/companies-and-charities/reliefs-and-exemptions/research-and-development-rd-tax-credit/how-to-videos.aspx

Based on our professional experience, in recent years, the Revenue Commissioners are increasingly carrying out audits in relation to a R&D tax credit claims.  Accounts Advice Centre provides a full and comprehensive audit support service.  For further information, please contact us at queries@accountsadvicecentre.ie

Please be aware that the information contained in this article is of a general nature.  It is not intended to address specific circumstances in relation to any individual or entity. All reasonable efforts have been made by Accounts Advice Centre to provide accurate and up-to-date information, however, there can be no guarantee that such information is accurate on the date it is received or that it will continue to remain so. This information should not be acted upon without full and comprehensive, specialist professional tax advice.

Revenue Compliance Intervention. Revenue Audits and Investigations. Revenue code of Practice. Income Tax, VAT, Employer’s Taxes, Corporation Tax.

Today, 9th April 2025, the Revenue Commissioners updated their guidance material in relation to the Code of Practice and Compliance.  Please click link: https://www.revenue.ie/en/self-assessment-and-self-employment/code-of-practice-and-compliance/index.aspx

As you’re aware, the Code of Practice for Revenue Compliance Interventions is a set of guidelines on how the Revenue Commissioners conduct compliance interventions.  It covers all aspects of compliance including your right to make a qualifying disclosure.

A qualifying disclosure must contain complete information and full particulars in relation to the tax liability arising under each relevant tax head.  It should be in writing and signed by the taxpayer and should also be accompanied by the correct tax payment plus corresponding interest.

Taxpayers are advised to make a qualifying disclosure to:

1. lower the level of tax penalty,

2. prevent the settlement from being published by Revenue and thereby avoid your name appearing as a Tax Defaulter, and

3. prevent prosecution as the Revenue Commissioners, generally, won’t initiate an investigation with a view to prosecution.

At Accounts Advice Centre, we have extensive, specialist experience in effectively handling Revenue enquiries. We manage all communications with the Revenue Commissioners in respect of the compliance intervention. We carry out health checks to identify areas for concern, prepare Qualifying Disclosures and seek to mitigate interest and penalties.  If you have received a Notification and require our help, please contact us at queries@accountsadvicecentre.ie

Please be aware that the information contained in this article is of a general nature.  It is not intended to address specific circumstances in relation to any individual or entity. All reasonable efforts have been made by Accounts Advice Centre to provide accurate and up-to-date information, however, there can be no guarantee that such information is accurate on the date it is received or that it will continue to remain so. This information should not be acted upon without full and comprehensive, specialist professional tax advice.