Finance Bill 2023 (the Bill), published on 19 October, includes the legislative provisions for the tax measures announced as part of Budget 2024 as well as introducing new measures and amendments to the Irish tax code. Here we focus on the measures not announced as part of Budget 2024 and the more significant measures contained in the Bill.
The Bill runs to 98 sections and over 270 pages. The scale of the Bill is primarily a result of the signalled new legislation required to transpose the EU Minimum Tax Directive and OECD Model Rules and guidance relating to the implementation of the Pillar Two minimum effective tax rate for large groups and companies.
Certain measures announced in Budget 2024, including notably the Capital Gains Tax Relief for Angel Investors, are being deferred with the introduction to be at Committee Stage of the Bill.
The Bill provides for the implementation of the Pillar Two minimum effective tax rate for large groups and companies by transposing the EU Minimum Tax Directive on ensuring a global minimum level of tax for MNE groups and large domestic groups into Irish law. The key points are:
The Bill is scheduled to be debated in the Dáil over the coming weeks and is due to pass to the Seanad at the end of November. A common budgetary timeline applies to all EU Member States, which means that this Bill will be enacted by the end of the year. In recent years the president has signed the Bill into law shortly before Christmas.
