Finance Bill 2025 Ireland – Increasing Revenue Powers

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/

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