Revenue has created a new Tax and Duty Manual regarding opinions provided by the High Wealth and Finance Services Division. A new procedure applies whereby all such applications must be submitted on a fully completed Form RTS 1A. The treatment for Financial Services branches remains the same as before. Further information is available in eBrief No.330/24.

Revenue has updated the Tax and Duty Manual regarding the general rule as to the deduction of expenses in employment. New guidance is provided on how to make a claim for employment expenses in respect of actual vouched expenses incurred wholly, exclusively and necessarily in the performance of the duties of employment that are outside the flat rate expense (FRE) allowance regime (paragraph 3). New detailed guidance is also provided on how to make a claim for a FRE allowance together with details of eight employment categories in which the FRE increased with effect from 1 January 2023 (paragraph 7). The manual has also been updated as follows: the circumstances where expenditure on a course is regarded as relevant to the business of an employer for the purpose of deciding whether the cost of such courses is regarded as a taxable benefit when paid for or reimbursed by an employer (paragraph 5), and the deductibility of typical expenses (paragraph 6).

Revenue has updated the Tax and Duty Manual which provides guidelines for VAT registration with information for VAT-registered applicants subsequently applying for postponed accounting via ROS. The Tax and Duty Manual which sets out the guidelines for registration for income tax, corporation tax, relevant contracts tax, employers’ PAYE and certain other tax heads has also been updated to reflect re-naming of the National Employer Helpline to the National Employer Helpdesk.

Revenue has updated the Tax and Duty Manual which outlines the procedures for agents or advisors acting on behalf of taxpayers. As previously advised, Revenue is ending the practice, generally known as the “A2” process, of making repayments of income tax and/or USC to the bank accounts of tax agents, rather than directly to taxpayers. 

Section 599 TCA 1997 provides for relief from capital gains tax (CGT) on the transfer by an individual, who has attained 55 years of age, of certain business or agricultural assets to a “child”, as defined in the section. Revenue has updated the Tax and Duty Manual which provides guidance on section 599 to reflect the Finance Act 2024 amendments. The key changes are: To provide the option to an individual to defer the CGT liability arising on such a disposal made on or after 1 January 2025, as the value of the assets exceeds the €10 million limit on relief granted, To provide for a general anti-avoidance provision in respect of relief granted on transfers of qualifying assets from an individual to a child, and the potential deferral of CGT arising in respect of such transfers, and To provide new and updated examples and information on the operation of the relief, and a restructuring of the content for ease of reference.

Revenue has updated the Tax and Duty Manual which contains an overview of the administration of Pillar Two,  the global minimum level of taxation for multinational enterprise groups and large-scale domestic groups. The updated guidance reflects amendments to Part 4A TCA 1997 contained in Finance Act 2024 as follows: clarification of the meaning of a “designated filing entity” (Section 2.3), clarification that the specified return date of an entity shall be 30 June 2026 where the specified return date of that entity, or group, would otherwise arise before 30 June 2026 (Section 2.8), clarification that the notification date of an entity or group shall be 31 December 2025 where a registration notification date of that entity, or group, arises before 31 December 2025 (Section 3), clarification that GloBE taxes fall due and payable on 30 June 2026 where the specified return date would otherwise arise before 30 June 2026 (Section 13), Table 1 - five year elections provides for the allocation of deferred tax expense election (Section 19.1), and Table 2 - annual elections provides for the simplified calculations safe harbour election (Section 19.2). Revenue has also updated the Tax and Duty Manual which provides guidance in relation to the operation of the Pillar Two rules as follows: widely held investment funds, master-feeder investment funds and umbrella fund/sub fund structures (Section 5.1), the interaction of tax residency and location of a constituent entity in certain circumstances (Section 5.4), the interaction of Part 35A TCA 1997 and Section 111P(4) TCA 1997 (Section 7.2). refundable and marketable transferable tax credits and intra-group financing arrangements (Section 7.2), and identifying the "ownership holder" referred to in Section 111AQ(1) TCA 1997 (Section 11.1). Revenue has advised that this manual will be further updated in due course to reflect the amendments made to Part 4A by Finance Act 2024.

Revenue has updated the Tax and Duty Manual regarding the Vacant Homes Tax (VHT) to provide for the increase in the rate of VHT from five times to seven times the basic rate of local Property Tax. The rate change applies for the chargeable period from 1 November 2024 to 31 October 2025 and all future chargeable periods.

Revenue has published updated Capital Acquisitions Tax Manuals to reflect the following Finance Act 2024 amendments: Reporting requirement in relation to gifts in respect of certain loans to include certain low-interest loans with effect from 1 January 2025, and Capital acquisitions tax exemptions to include certain ex-gratia payments made under the cervical check non-disclosure ex-gratia scheme and payments made under phase 1 of the Stardust ex-gratia payment scheme.  

Revenue has updated several manuals to reflect amendments introduced in Finance Act 2024, as well publishing a new manual on the VAT treatment of heat pump heating systems.  The updated manuals are as follows: VAT treatment of Food and Drink supplied by wholesalers and retailers clarifies that the standard rate of VAT applies to juice extracted from, and other drinkable products derived from, fruit, vegetables, plants, grains, seeds, or pulses and, that milk substitute drinks derived from plants will continue to be subject to the zero rate of VAT, Management of special investment funds clarifies that the management of an Irish Alternative Investment Fund (AIF) managed by an Irish AIF Manager (AIFM) is covered by the fund management exemption. The exemption also applies to the management of an Irish AIF managed by a non-Irish AIFM including where the AIFM is registered with a competent authority of a Member State, VAT treatment of the special flat-rate scheme for farmers includes the new flat rate addition rate of 5.1 percent, Construction services includes a consequential amendment arising from the application of the second reduced rate to the supply and installation of low emissions heat pump heating systems.  

The rates of Stamp Duty applying to the acquisition of residential property were increased by section 90 Finance Act 2024 and apply to instruments executed on or after 2 October 2024. The revised standard rates are: 1 percent on the consideration up to €1 million, 2 percent on any consideration exceeding €1 million up to €1.5 million, and 6 percent on any consideration exceeding €1.5 million. This section also provides that the new 6 percent rate will not apply on the acquisition of three or more apartments in the same apartment block. In addition to the standard rates, the higher rate of stamp duty to be charged on the acquisition of 10 or more residential properties, excluding apartments, in any 12-month period, increased from 10 percent to 15 percent. The following Stamp Duty Manuals have been updated to reflect these changes: guidance on shares deriving value from immovable property situated in the State under Section 31C SDCA 1999, Schedule 1 – stamp duties on instruments, Section 83DA - repayment of stamp duty under affordable dwelling purchase arrangements, Section 83DB – repayment of stamp duty in respect of certain residential units, and Section 31E – stamp duty on certain acquisitions of residential property. In addition to the above, Notes for guidance - Stamp Duty 2024 have been published, which reflect the Finance Act 2024 changes to the Stamp Duties Consolidation Act 1999.

Revenue has updated several Tax and Duty Manuals to reflect amendments introduced in Finance Act 2024. The updated guidance includes the manual on Outbound Payments and the guidance on foreign pension lump sums. Outbound payments defensive measures manual has been updated regarding excluded payments, and instances under Section 817U(6) TCA 1997 where a tax transparent entity and its owners/members are located in the same territory. In addition, example 5.1.2 has been revised to provide clarification on the association test as it applies in that example, Guidance on the taxation of foreign retirement lump sums reflects the amended definition of "standard chargeable amount" in Section 790AA TCA 1997 to mean €500,000 less the tax free amount, currently €200,000 (Paragraph 4.3.1 ), effective from 1 January 2025, Central Electronic System of Payment Information (CESOP) reflects the provision for a penalty regime for non-compliance by Payment Service Providers with their obligations under Part 9A VATCA 2010,   Dependent Relative Tax Credit - from 1 January 2025 the value of the credit will increase to €305, and the "specified amount" will increase to €18,028, Home Carers Tax Credit - from 1 January 2025 the value of the credit amounts to €1,950, Blind Person's Tax Credit - from 1 January 2025 the value of the credit amounts to €1,950 per qualifying individual, Single Person Child Carer Credit - from 1 January 2025 the value of the credit amounts to €1,900, and PAYE/USC Regulations - Emergency Tax has been updated to reflect the increase in tax rates and tax bands for 2025.

Revenue has updated the Tax and Duty Manual on the Research and Development tax credit to incorporate the Finance Act 2024 amendment to the first instalment threshold. Section 766C was amended to increase the first instalment threshold amount from €50,000 to €75,000. The amendment applies in respect of accounting periods commencing on or after 1 January 2025,  The manual has also been updated to include examples to reflect the increased first instalment threshold amount. Any relevant existing examples in the manual have been updated accordingly.