Finance Act 2024

Type Act

Publication 2024-11-12

State In force

Source Irish Statute Book

articles 118

“ ‘remote betting intermediary’s licence’ means a licence issued under section 7C (inserted by section 14 of the Betting (Amendment) Act 2015) of the Betting Act 1931;”,

(h) by the substitution of the following definition for the definition of “remote bookmaker’s licence”:

“ ‘remote bookmaker’s licence’ means a licence issued under section 7B (inserted by section 14 of the Betting (Amendment) Act 2015) of the Betting Act 1931;”,

(i) by the substitution of the following definition for the definition of “remote means”:

“ ‘remote means’ means any means by which it is possible for a person to communicate and transact with a person in another physical location, regardless of the actual physical location of those persons, and includes—

(a) the internet,

(b) a telephone,

(d) telegraphy (whether or not wireless telegraphy);”,

(j) by the substitution of the following definition for the definition of “totalisator”:

“ ‘totalisator’ means an apparatus or organisation by means of which an unlimited number of persons can each stake money in respect of a future event on the terms that the amount to be won by the successful stakers is dependent on or to be calculated with reference to the total amount staked by means of the apparatus or organisation in relation to that event but not necessarily on the same contingency, and includes all offices, tickets, recorders, and other things ancillary or incidental to the working of the apparatus or organisation;”,

and

(k) by the insertion of the following definitions:

“ ‘bet’ means a transaction involving 2 or more persons, where—

(a) the parties hold differing views regarding the outcome of an event,

(b) the parties agree that depending on the outcome of the event, one or more parties shall pay to the other or others a sum, and

(c) the event upon the outcome of which the transaction depends shall not be the outcome of a game within the meaning of this Act;

‘bookmaker’s licence’ means a licence issued—

(a) under subsection (3) of section 7 (inserted by section 13 of the Betting (Amendment) Act 2015) of the Betting Act 1931, or

(b) in accordance with section 7A (inserted by subsection (2) of section 64 of the Irish Horseracing Industry Act 1994) of the Betting Act 1931;

‘game’ means a game (whether of skill or chance or partly of skill and partly of chance) for stakes hazarded by the players;

‘licensed bookmaker’ means a person who is the holder of a bookmaker’s licence or a remote bookmaker’s licence as the case may be;”.

72. Amendment of section 67 of Finance Act 2002 (betting duty)

72. (1) Section 67 of the Finance Act 2002 is amended—

(a) by the substitution of “licensed bookmaker” for “bookmaker” in each place where it occurs, and

(b) by the substitution of the following subsection for subsection (1A):

“(1A) For the avoidance of doubt, betting duty imposed by subsection (1) is chargeable on all bets placed by a person with a licensed bookmaker other than by remote means.”.

(2) Subsection (1) shall have effect from 1 January 2025.

73. Amendment of section 67A of Finance Act 2002 (application of betting duty to remote bookmakers)

73. (1) The Finance Act 2002 is amended by the substitution of the following section for section 67A:

“Remote betting duty

67A. (1) There shall be charged, levied and paid on and by every licensed bookmaker who makes, lays or otherwise enters into any bets by remote means with persons in the State an excise duty (in this Chapter referred to as ‘remote betting duty’) at the rate of 2 per cent on the amount of every bet entered into by him or her.

(2) For the purpose of this section the amount of a bet shall be—

(a) the sum of money or the open market value of other consideration which by the terms of the bet the licensed bookmaker will be entitled to receive, retain, or take credit for if the event the subject of the bet is determined in his or her favour, or

(b) where the amount cannot be determined in accordance with paragraph (a) at the time the bet is placed, the amount of the unit stake.

(3) Notwithstanding subsection (2), where a bet is placed by a person in pursuance of an offer which permits the person to pay nothing or less than the amount which that person would have been required to pay without the offer, the amount of the bet shall be equal to the amount of the unit stake.

(4) Whenever it is proved to the satisfaction of the Revenue Commissioners—

(a) that a bet in respect of which the duty imposed by this section is chargeable has become void for any reason other than the mutual consent of the parties thereto, or

(b) that the amount of a bet in respect of which the said duty is chargeable is calculated in accordance with subsection (2)(a) has not been and is not likely to be collected by the licensed bookmaker,

the Revenue Commissioners may, subject to such conditions as they may think fit to impose, either (as the case may require) repay the duty paid or remit the duty chargeable in respect of such bet.

(5) (a) Subject to paragraph (b) and to such conditions as the Revenue Commissioners may prescribe or otherwise impose, a licensed bookmaker shall not be liable for remote betting duty on a bet made, laid or otherwise entered into by the licensed bookmaker where it is shown to the satisfaction of the Revenue Commissioners to have been transferred by that licensed bookmaker to another licensed bookmaker and accepted by the other licensed bookmaker.

(b) Where paragraph (a) applies, the bet so transferred shall, from the time it is accepted by that other bookmaker, be liable to remote betting duty under subsection (1) and that other bookmaker shall be liable for payment of the remote betting duty.

(6) Every person who fails or neglects to pay, any sum payable by him or her in respect of remote betting duty imposed by this section within the prescribed period, shall be guilty of an offence and shall be liable on summary conviction to an excise penalty of €5,000.”.

(2) Subsection (1) shall have effect from 1 January 2025.

74. Amendment of section 68A of Finance Act 2002

74. Section 68A of the Finance Act 2002 is amended by the substitution of “Commission Regulation (EU) 2023/2831” for “Commission Regulation (EU) No. 1407/2013” in each place where it occurs.

75. Amendment of Chapter 1 of Part 2 of Finance Act 2002 (licence duty)

75. (1) Chapter 1 of Part 2 of the Finance Act 2002 is amended—

(a) in section 65, by the substitution of “€250” for “€500”,

(b) in section 66—

(i) in subsection (1), by the substitution of “€380” for “€760”, and

(ii) in subsection (3), by the substitution of “€380” for “€760”,

(i) subsection (1)(a), by the substitution of “€5,000” for “€10,000”, and

(ii) by the substitution of the following Table for the Table to that section:

“Table

Level of annual turnover Rates of duty (1)	Under €50 million €5,000 (2)
€50 million or more but less than €75 million	€10,000
€75 million or more but less than €100 million	€15,000
€100 million or more but less than €150 million	€20,000
€150 million or more but less than €200 million	€30,000
€200 million or more but less than €300 million	€40,000
€300 million or more but less than €400 million	€60,000
€400 million or more but less than €500 million	€80,000
€500 million or more	€100,000

”,

(d) in section 66B—

(i) in subsection (1)(a), by the substitution of “€5,000” for “€10,000”, and

(ii) by the substitution of the following Table for the Table to that section:

“Table

Level of annual commission earnings (1)	Rates of duty (2)
Under €3 million	€5,000
€3 million or more but less than €4,500,000	€10,000
€4,500,000 or more but less than €6 million	€15,000
€6 million or more but less than €9 million	€20,000
€9 million or more but less than €12 million	€30,000
€12 million or more but less than €18 million	€40,000
€18 million or more but less than €24 million	€60,000
€24 million or more but less than €30 million	€80,000
€30 million or more	€100,000

”,

(e) by the substitution of the following section for section 66C:

“Payment arrangements for excise duty payable under section 65, 66A or 66B

66C. The excise duty payable under section 65, 66A or 66B, as the case may be, shall be paid in full at the time of the granting or renewal of the licence.”,

(f) by the substitution of the following section for section 66D:

“Payment arrangements for excise duty payable under section 66

66D. The excise duty payable under section 66 on the registration or renewal of the registration of a premises shall be paid in full at the time of the registration or renewal of the registration.”,

and

(g) in section 78(5)(c), by the substitution of “€1,000” for “€2,000”.

(2) Subsection (1) shall come into operation on such day or days as the Minister for Finance may appoint by order.

76. Amendment of section 132 of Finance Act 1992 (charge of excise duty)

76. (1) Section 132(3) of the Finance Act 1992 is amended—

(a) by the substitution of the following paragraph for paragraph (c):

“(c) in case it is a category B vehicle—

(i) in case it is a vehicle in respect of which the level of CO2 emissions measured in the manner referred to in subparagraph (ii) of paragraph (a) of the definition of “CO2 emissions” in section 130 is confirmed by reference to any document produced in support of the declaration for registration, by reference to Table 3 to this subsection,

(ii) where—

(I) the level of CO2 emissions cannot be confirmed by reference to the relevant EC type-approval certificate, EC certificate of conformity or vehicle registration certificate issued in another Member State, and

(II) the Commissioners are not satisfied of the level of CO2 emissions by reference to any other document produced in support of the declaration for registration,

at the rate of an amount equal to the highest percentage specified in Table 3 to this subsection of the value of the vehicle or €266, whichever is the greater, or

(iii) in case it is a vehicle in respect of which the level of CO2 emissions measured in the manner referred to in subparagraph (i) or (iii) of paragraph (a), or paragraph (b), of the definition of “CO2 emissions” in section 130 is confirmed by reference to any document produced in support of the declaration for registration and the level of CO2 emissions measured in the manner referred to in subparagraph (ii) of paragraph (a) of that definition is not so confirmed, by reference to Table 3 to this subsection, subject to the modification that the CO2 emissions for the vehicle shall be adjusted—

(I) in respect of such a vehicle designed to use heavy oil as a propellant, in accordance with the following formula:

X(0.9498) + 41.539,

(II) in respect of any other such vehicle, in accordance with the following formula:

X(1.0105) + 18.335,

where X is the level of carbon dioxide emissions for the vehicle measured in the manner referred to in subparagraph (i) or (iii) of paragraph (a), or paragraph (b), as the case may be, of the definition of “CO2 emissions” in section 130,

and where, in respect of a vehicle, more than one level of carbon dioxide emissions is measured in the manner referred to in a subparagraph or paragraph of the definition of “CO2 emissions” in section 130, the highest level of carbon dioxide emissions measured in that manner shall be the CO2 emissions for the vehicle for the purpose of subparagraph (i) or (iii), as the case may be,”,

(b) by the substitution of the following paragraph for paragraph (d):

“(d) in case it is—

(i) a category C vehicle, or

(ii) a vehicle that, at all stages of manufacture, is classified as a category N1 vehicle with less than 4 seats and—

(I) has at any stage of manufacture, a technically permissible maximum laden mass that is greater than 130 per cent of the mass of the vehicle with bodywork in running order, or

(II) is an electric vehicle that has, at any stage of manufacture, a technically permissible maximum laden mass that is greater than 125 per cent of the mass of the vehicle with bodywork in running order,

at the rate of €200,”,

and

“Table 3

CO2 emissions (CO2 g/km)	Percentage payable of the value of the vehicle
0g/km up to and including 120g/km	8% or €160 whichever is the greater
More than 120g/km	13.3% or €266 whichever is the greater

”.

(2) Subsection (1)(b) shall come into operation on 1 January 2025.

(3) Subsection (1)(a) and (c) shall come into operation on 1 July 2025.

PART 3 Value-Added Tax

77. **Interpretation (Part 3)**

77. In this Part, “Principal Act” means the Value-Added Tax Consolidation Act 2010.

78. Amendment of section 2 of Principal Act

78. Section 2(1) of the Principal Act is amended, with effect from 1 January 2025—

(a) in the definition of “goods threshold”, by the substitution of “€85,000” for “€80,000”, and

(b) in the definition of “services threshold”, by the substitution of “€42,500” for “€40,000”.

79. Amendment of section 46 of Principal Act (rates of tax)

79. Section 46(1) of the Principal Act is amended—

(a) in paragraph (ca), by the substitution of “paragraphs 7(a), 7A, 12 and 12A” for “paragraphs 7(a), 7A and 12” with effect as on and from 1 January 2025, and

(b) in paragraph (caa), by the substitution of “30 April 2025” for “31 October 2024” with effect as on and from 2 October 2024.

80. Amendment of section 59 of Principal Act (deduction for tax borne or paid)

80. Section 59(3) of the Principal Act is amended—

(a) in paragraph (a), by the substitution of “section 9(4) or 12(3),” for “section 9(4) or 12(3), or”,

(b) in paragraph (b), by the substitution of “by him or her, or” for “by him or her.”, and

“(c) an accountable person referred to in section 22(3) or 28(4), or a taxable person who is deemed to have supplied a letting in accordance with section 28(5), in respect of supplies to which those sections apply.”.

81. Amendment of section 60 of Principal Act (general limits on deductibility)

81. Section 60(2) of the Principal Act is amended, in paragraph (a), by the substitution of the following subparagraph for subparagraph (i):

“(i) expenditure incurred by the accountable person on food or drink, or accommodation (other than qualifying accommodation in connection with attendance at a qualifying conference), or other personal services, for the accountable person, the accountable person’s agents or employees, except to the extent (if any) that such expenditure is incurred for the purposes of a supply of services, being the provision of food or drink, or accommodation, or other personal services, in respect of which that accountable person is accountable for tax,”.

82. Amendment of section 76 of Principal Act (returns and remittances)

82. Section 76 of the Principal Act is amended, in subsection (2)(a)(i)(I), by the insertion of “, and the amount (if any) which would have been deductible therefrom in accordance with Chapter 1 of Part 8 but for the application of section 59(3)(c),” after “tax which became due”.

83. Amendment of section 86 of Principal Act (special provisions for tax invoiced by flat-rate farmers)

83. Section 86(1) of the Principal Act is amended, with effect from 1 January 2025, by the substitution of “5.1 per cent” for “4.8 per cent”.

84. Amendment of section 115 of Principal Act (penalties generally)

84. Section 115 of the Principal Act is amended by the insertion of the following subsection after subsection (1B):

“(1C) (a) In this subsection, ‘payment service provider’ has the same meaning as it has in section 85A.

(b) A payment service provider who does not comply with section 85C, 85F or 85G, as the case may be, shall be liable to a penalty of €4,000 in respect of the calendar quarter during which the payment service provider failed to comply with the section concerned and to a further penalty of €4,000 for each subsequent calendar quarter during which that payment service provider has failed to comply with that section.

85. Amendment of paragraph 6(2) of Schedule 1 to Principal Act (other exempted activities)

85. Schedule 1 to the Principal Act is amended, in Part 2, in paragraph 6(2)(ed), by—

(a) the insertion of “or registered with” after “authorised by”, and

(b) the substitution of “a Member State” for “another Member State”.

86. Amendment of paragraphs 4 and 6 of Schedule 2 to Principal Act (zero-rated goods and services)

86. The Principal Act is amended, with effect from 1 January 2025, in Part 1 of Schedule 2—

(a) in paragraph 4, by the deletion of subparagraphs (1) and (6), and

(b) in paragraph 6(2), by the deletion of clause (c).

87. Amendment of Schedule 2 to Principal Act (zero-rated goods and services)

87. Schedule 2 to the Principal Act is amended with effect from 1 January 2025, in Part E of Table 1 to paragraph 8(1)—

(a) in item (a) of column (1), by the substitution of “fruit, vegetables, plants, grains, seeds, or pulses” for “fruit or vegetables”, and

(b) in column (2), by the insertion of the following item after item (d):

“(e) Oat milk, almond milk, rice milk, coconut milk, hemp milk, cashew milk, soy milk, pea milk, hazelnut milk, flax milk, potato milk or other similar milk substitute drinks.”.

88. Amendment of Schedule 3 to Principal Act (goods and services chargeable at the reduced rate)

88. The Principal Act is amended, with effect as on and from 1 January 2025, in Schedule 3—

(a) in Part 2—

(i) in paragraph 9(1), by the insertion of “or the supply and installation of low emissions heat pump heating systems as specified in paragraph 12A,” after “Schedule 2”, and

(ii) by the insertion of the following paragraph after paragraph 12:

“Low emissions heat pump heating systems

12A. The supply and installation of low emissions heat pump heating systems.”,

and

(b) in Part 4, in paragraph 15(2), by the insertion of “other than the supply and installation of low emissions heat pump heating systems as specified in paragraph 12A,” after “(including the installation of fixtures),”.

PART 4 Stamp Duties

89. **Interpretation (Part 4)**

89. In this Part, “Principal Act” means the Stamp Duties Consolidation Act 1999.

90. Amendment to stamp duty rates in respect of residential property

90. (1) The Principal Act is amended—

(a) in section 83DB(1), in the definition of “relevant instrument”, by the deletion of “, where the instrument was chargeable, in respect of the whole or part of the consideration under the instrument, to stamp duty at a rate of 10 per cent”, and

(b) in Schedule 1—

(i) in the Heading “CONVEYANCE or TRANSFER on sale of any property other than stocks or marketable securities or a policy of insurance or a policy of life insurance”, by the substitution of the following paragraph for paragraph (1):

“

(1) (a) In this paragraph, ‘apartment block’, ‘relevant residential unit’ and ‘residential unit’ have the same meaning, respectively, as they have in section 31E. (b) Where the amount or value of the consideration for the sale is wholly or partly attributable to residential property and the transaction effected by that instrument does not form part of a larger transaction or of a series of transactions in respect of which, had there been a larger transaction or a series of transactions, the amount or value, or the aggregate amount or value, of the consideration (other than the consideration for the sale concerned which is wholly or partly attributable to residential property) would have been wholly or partly attributable to residential property:
(i) for the consideration which is attributable to— (I) not more than 2 residential units in an apartment block, or (II) residential property which is not a relevant residential unit;	1 per cent of the first €1,000,000 of the consideration, 2 per cent of the next €500,000 of the consideration and 6 per cent of the balance of the consideration thereafter, but where the calculation results in an amount which is not a multiple of €1 the amount so calculated shall be rounded down to the nearest €.
(ii) for the consideration which is attributable to 3 or more residential units in an apartment block;	1 per cent of the first €1,000,000 of the consideration and 2 per cent of the balance of the consideration thereafter, but where the calculation results in an amount which is not a multiple of €1 the amount so calculated shall be rounded down to the nearest €.
(iii) for the consideration which is attributable to a relevant residential unit.	15 per cent of the consideration, but where the calculation results in an amount which is not a multiple of €1 the amount so calculated shall be rounded down to the nearest €.

”,

and

(ii) in the heading ‘LEASE’, by the substitution of the following clause for clause (i) of paragraph (3)(a):

“

(i) the amount or value of such consideration for the lease is wholly or partly attributable to residential property and the transaction effected by that instrument does not form part of a larger transaction or of a series of transactions in respect of which, had there been a larger transaction or a series of transactions, the amount or value, or the aggregate amount or value, of the consideration (other than the consideration for the lease concerned which is wholly or partly attributable to residential property and other than rent) would have been wholly or partly attributable to residential property:
(I) for the consideration which is attributable to— (A) not more than 2 residential units (within the meaning of section 31E) in an apartment block (within the meaning of section 31E), or (B) residential property which is not a relevant residential unit (within the meaning of section 31E);	1 per cent of the first €1,000,000 of the consideration, 2 per cent of the next €500,000 of the consideration and 6 per cent of the balance of the consideration thereafter, but where the calculation results in an amount which is not a multiple of €1 the amount so calculated shall be rounded down to the nearest €.
(II) for the consideration which is attributable to 3 or more residential units (within the meaning of section 31E) in an apartment block (within the meaning of section 31E);	1 per cent of the first €1,000,000 of the consideration and 2 per cent of the balance of the consideration thereafter, but where the calculation results in an amount which is not a multiple of €1 the amount so calculated shall be rounded down to the nearest €.
(III) for the consideration which is attributable to a relevant residential unit (within the meaning of section 31E).	15 per cent of the consideration, but where the calculation results in an amount which is not a multiple of €1 the amount so calculated shall be rounded down to the nearest €.

”.

(2) Subsection (1)—

(a) shall have effect as respects instruments executed on or after 2 October 2024, and

(b) shall not have effect as respects any instrument executed before 1 January 2025, where—

(i) the effect of the application of paragraph (b) of subsection (1) would be to increase the duty otherwise chargeable on the instrument, and

(ii) the instrument contains a statement, in such form as the Revenue Commissioners may specify, certifying that the instrument was executed solely in pursuance of a binding contract entered into before 2 October 2024.

(3) The furnishing of an incorrect certificate for the purposes of subsection (2)(b)(ii) shall be deemed to constitute the delivery of an incorrect statement for the purposes of section 1078 of the Taxes Consolidation Act 1997.

91. Amendment of section 31E of Principal Act (stamp duty on certain acquisitions of residential property)

91. Section 31E of the Principal Act is amended by the insertion of the following subsection after subsection (12):

“(12A) Subsection (12) shall not apply to a conveyance or transfer on sale of shares in the National Asset Residential Property Services DAC, on or before 31 December 2025, by the National Asset Management Agency or a NAMA group entity (within the meaning of the National Asset Management Agency Act 2009), as the case may be, to the Land Development Agency.”.

92. Farming reliefs

92. The Principal Act is amended—

(a) in section 81AA—

(i) in subsection (1), by the insertion of the following definitions:

“ ‘ordinary share capital’, in relation to a company, means all the issued share capital (by whatever name called) of the company, other than capital the holders of which have a right to a dividend at a fixed rate, but have no other right to share in the profits of the company;

‘relevant period’, in relation to an instrument, means a period of 5 years—

(a) in a case where subsection (7) applied to the instrument, commencing on the date of execution of that instrument, or

(b) in a case where subsection (11) applied to the instrument, commencing on the date the claim for repayment is made to the Commissioners;”,

(ii) in subsection (12)(a), by the substitution of the following subparagraph for subparagraph (i):

“(i) disposes of such land, or part of such land (in this subsection referred to as a ‘part disposal’), within the relevant period, and”,

and

(iii) by the insertion of the following subsections after subsection (13):

“(13A) Where any person to whom land was conveyed or transferred by any instrument to which subsection (7) or (11) applied fails to spend not less than 50 per cent of his or her normal working time farming the land concerned during the relevant period then such person or, where there is more than one such person, each such person, jointly and severally, shall become liable to pay to the Commissioners—

(a) the amount of the stamp duty that would have been charged on that instrument had subsection (7) not applied or, as the case may be, the amount of stamp duty that was charged on the instrument in the first instance and later repaid under subsection (11)(c), and

(b) interest calculated in accordance with section 159D from the date when the failure occurs to the date when the duty is remitted.

(13B) For the purposes of subsection (13A), where, for any part of the relevant period, the land concerned is leased to a company and the person referred to in that subsection—

(a) spends not less than 50 per cent of his or her normal working time farming the land as an employee of the company,

(b) holds not less than 20 per cent of the ordinary share capital of the company,

(d) has the ability to participate in the financial and operational decisions of the company,

the person shall, for that part of the relevant period, be treated as having spent not less than 50 per cent of his or her normal working time farming the land.”,

and

(b) in section 81D—

(i) by the substitution of the following subsection for subsection (1):

“(1) In this section—

‘Commission Regulation (EU) No. 1408/2013’ means Commission Regulation (EU) No. 1408/2013 of 18 December 2013[^32] as amended by Commission Regulation (EU) 2019/316 of 21 February 2019[^33] and Commission Regulation (EU) 2022/2046 of 25 October 2022[^34];

‘farming’ includes the occupation of woodlands on a commercial basis;

‘ordinary share capital’, in relation to a company, means all the issued share capital (by whatever name called) of the company, other than capital the holders of which have a right to a dividend at a fixed rate, but have no other right to share in the profits of the company.”,

(ii) by the substitution of the following subsection for subsection (4):

“(4) For the purposes of this section, the lessee shall, from the date on which the lease is executed, be—

(a) an individual who—

(i) is the holder of or, within a period of 4 years from the date of the lease, will be the holder of, a trained farmer qualification (within the meaning given by section 654A of the Taxes Consolidation Act 1997) or a qualification set out in Schedule 2 or 2A, or

(ii) spends not less than 50 per cent of his or her normal working time farming land (including the leased land),

(b) a company, in respect of which at least one individual is an individual—

(i) who holds not less than 20 per cent of the ordinary share capital of the company,

(ii) who is a director of the company,

(iii) who has the ability to participate in the financial and operational decisions of the company, and

(iv) who—

(I) is the holder of or, within a period of 4 years from the date of the lease, will be the holder of, a trained farmer qualification (within the meaning given by section 654A of the Taxes Consolidation Act 1997) or a qualification set out in Schedule 2 or 2A, or

(II) spends not less than 50 per cent of his or her normal working time farming land (including, as an employee of the company, the leased land).”,

(iii) in subsection (6), by the substitution of “the individual referred to in paragraph (a) or (b), as the case may be, of subsection (4), or the permanent incapacity of that individual” for “the lessee or the permanent incapacity of the lessee”, and

(iv) by the insertion of the following subsection after subsection (6):

“(7) Relief under this section shall be available to a single undertaking within the meaning of Commission Regulation (EU) No. 1408/2013 only insofar as it does not exceed the ceiling of aid laid down in that Commission Regulation.”.

93. Stamp duties modernisation

93. The Principal Act is amended—

(a) by the repeal of sections 94, 102, 114 to 122 and 125B,

(b) in section 100, by the substitution of “Temple Bar Cultural Trust Designated Activity Company” for “Temple Bar Properties Limited” in each place where it occurs, and

“104. (1) Stamp duty shall not be chargeable on—

(a) (i) a licence granted (whether before or after the commencement of, or by virtue of, section 21 of the Climate Action and Low Carbon Development (Amendment) Act 2021) under section 8 or 9,

(ii) a lease granted (whether before or after the commencement of, or by virtue of, section 21 of the Climate Action and Low Carbon Development (Amendment) Act 2021) under section 13, or

(iii) a licence granted under section 19,

of the Petroleum and Other Minerals Development Act 1960, or

(b) an instrument for the sale, assignment or transfer of any licence or lease referred to in paragraph (a) or any right or interest in any such licence or lease.

(2) Subsection (1) shall apply as respects a licence or lease referred to in paragraph (a) or an instrument referred to in paragraph (b), of that subsection, where the licence, lease or instrument concerned is executed on or before 31 December 2029.”.

94. Provisions in relation to repayment of stamp duty

94. The Principal Act is amended—

(a) in section 31A(4), by the substitution of “shall, subject to section 159A, be repaid” for “shall be returned”, and

(b) in section 31B(3), by the substitution of “shall, subject to section 159A, be repaid” for “shall be returned”.

95. Banking levies modernisation

95. (1) The Principal Act is amended, in Part 9—

(a) in section 123B—

(i) by the substitution of the following subsection for subsection (5):

“(5) The duty charged by subsection (4) on a statement delivered by a promoter pursuant to subsection (2) shall be paid by the promoter on delivery of the statement.”,

and

(ii) by the insertion of the following subsection after subsection (13):

“(14) In this section, a reference to a card shall include a reference to a card in electronic form.”,

and

(b) in section 124—

(i) in subsection (2)—

(I) in paragraph (a)—

(A) by the substitution of the following definition for the definition of “account”:

“ ‘account’ means an account maintained by a promoter to which amounts in respect of goods, services or cash obtained by a person by means of a charge card or company charge card are charged;”,

(B) by the substitution of the following definition for the definition of “letter of closure”:

“ ‘letter of closure’, in relation to an account, means a letter, in such form as the Commissioners may specify, issued during a chargeable period by a promoter to an account holder in respect of an account which has been closed during the chargeable period confirming that the account holder has, during the chargeable period, accounted for the amount of stamp duty—

(i) which the promoter is required to pay in respect of the account for the chargeable period, or

(ii) which another promoter is required to pay for the chargeable period in respect of another account which has been closed during the chargeable period;”,

and

(II) by the substitution of the following paragraph for paragraph (b):

“(b) A promoter shall, within 3 months of the end of a chargeable period referred to in subparagraph (i) of the definition of ‘chargeable period’ in paragraph (a) and within one month of the end of a chargeable period referred to in subparagraph (ii) or (iii) of that definition, deliver to the Commissioners a statement showing in respect of accounts maintained by the promoter at any time during the chargeable period—

(i) the number of accounts that are replacement accounts, and

(ii) the number of accounts that are not replacement accounts.”,

(III) in paragraph (c), by the substitution of “each account included in the number of accounts” for “each charge card, company charge card and supplementary card included in the number of cards”,

(IV) by the substitution of the following paragraph for paragraph (d):

“(d) Notwithstanding paragraph (c), where a promoter maintains a replacement account at any time during a chargeable period, the promoter shall be exempt from stamp duty on that replacement account.”,

and

(V) in paragraph (e), by the substitution of “in respect of the account” for “in respect of the charge cards to which the account relates,”,

(ii) by the substitution of the following subsection for subsection (4):

“(4) (a) The duty charged by subsection (1)(c) on a statement delivered by a bank pursuant to subsection (1)(b) shall be paid by the bank on delivery of the statement.

(b) The duty charged by subsection (2)(c) on a statement delivered by a promoter pursuant to subsection (2)(b) shall be paid by the promoter on delivery of the statement.”,

(iii) in subsection (7)—

(I) by the deletion of “or by reference to the charge card, company charge card or supplementary card to which the account relates”, and

(II) by the substitution of “chargeable period” for “relevant period” in each place where it occurs,

and

(iv) by the insertion of the following subsection after subsection (8):

“(9) In this section, a reference to a card shall include a reference to a card in electronic form.”.

(2) The amendments effected by subparagraphs (i) and (iii)(I) of subsection (1)(b) shall not have effect as respects any statement that is required to be delivered by a promoter (within the meaning of section 124 of the Principal Act) to the Revenue Commissioners pursuant to section 124(2)(b) of the Principal Act on or before 31 January 2025.

96. Amendment of section 126AB of Principal Act (further levy on certain financial institutions)

96. Section 126AB of the Principal Act is amended—

(a) in subsection (1), by the substitution of the following definition for the definition of “base year”:

“ ‘base year’, in respect of each of the years 2024 and 2025, means the year 2022;”,

and

(b) by the substitution of the following subsection for subsection (2):

“(2) A relevant person shall, for each of the years 2024 and 2025, not later than the due date in relation to each such year, deliver to the Commissioners a statement showing the assessable amount.”.

PART 5 Capital Acquisitions Tax

97. **Interpretation (Part 5)**

97. In this Part, “Principal Act” means the Capital Acquisitions Tax Consolidation Act 2003.

98. Amendment of section 46 of Principal Act (delivery of returns)

98. (1) Section 46(4A) of the Principal Act is amended by the substitution of the following paragraph for paragraph (b):

“(b) This subsection shall apply to a specified loan where—

(i) a person is deemed under section 40(2) to have taken a gift in respect of the use or enjoyment of the specified loan, and

(ii) the balance outstanding on the specified loan, when aggregated with the balance outstanding on any other specified loan to which subparagraph (i) applies in the relevant period, exceeds €335,000 on at least one day in the relevant period.”.

(2) Subsection (1) shall come into operation on 1 January 2025.

99. Amendment of Schedule 2 to Principal Act (computation of tax)

99. (1) Schedule 2 to the Principal Act is amended in paragraph 1 of Part 1, in the definition of “group threshold”—

(a) in paragraph (a), by the substitution of “€400,000” for “€335,000”,

(b) in paragraph (b), by the substitution of “€40,000” for “€32,500”, and

(2) Subsection (1) applies to gifts and inheritances taken on or after 2 October 2024.

100. Further provisions relating to agricultural property

100. (1) The Principal Act is amended by the insertion of the following section after section 89:

“Further provisions relating to agricultural property

89A. (1) In this section—

‘agricultural property’ means—

(a) agricultural land, pasture and woodland situate in a Member State or in the United Kingdom and crops, trees and underwood growing on such land and also includes such farm buildings, farm houses and mansion houses (together with the lands occupied with such farm buildings, farm houses and mansion houses) as are of a character appropriate to the property, and farm machinery, livestock and bloodstock on such property, and

(b) a payment entitlement (within the meaning of Regulation (EU) 2021/2115 of the European Parliament and of the Council of 2 December 2021[^35]);

‘agricultural value’ means the market value of agricultural property reduced by 90 per cent of that value;

‘beneficiary’ means a donee, a successor or a transferee referred to in section 32(2);

‘relevant debts or encumbrances’ means any debt or encumbrance in respect of a dwelling-house that—

(a) is the only or main residence of the beneficiary, and

(b) is not agricultural property,

other than a loan secured on the dwelling-house which is not used to purchase, repair or improve the dwelling-house;

‘relevant qualification’ means a trained farmer qualification (within the meaning given by section 654A of the Taxes Consolidation Act 1997) or a qualification set out in Schedule 2 or 2A to the Stamp Duties Consolidation Act 1999;

‘solar panel’ means ground-mounted equipment used to capture solar energy and convert it into electrical energy together with ancillary equipment used to harness, store and transfer the electrical energy.

(2) Subject to this section, insofar as any gift or inheritance consists of agricultural property at the date of the gift or inheritance and at the valuation date, and—

(a) both the disponer and the beneficiary are individuals,

(b) for the period of not less than 6 years ending immediately prior to the date of the gift or inheritance—

(i) the disponer was beneficially entitled in possession to the agricultural property concerned, and

(ii) one of the conditions specified in subsection (5) was satisfied,

(c) at the valuation date, not less than 80 per cent of the market value of the property to which the beneficiary is beneficially entitled in possession, after taking the gift or inheritance, is represented by the market value of agricultural property situated in a Member State or in the United Kingdom and, for these purposes—

(i) no deduction is made from the market value of property for any debts or encumbrances other than relevant debts or encumbrances, and

(ii) an individual is deemed to be beneficially entitled in possession to—

(I) an interest in expectancy, notwithstanding the definition of ‘entitled in possession’ in section 2(1), and

(II) property that is subject to a discretionary trust under or in consequence of a disposition made by the individual where the individual is an object (within the meaning of Chapter 2 of Part 3) of the trust,

and

(d) for the period of not less than 6 years commencing on the valuation date, the beneficiary satisfies one of the conditions specified in subsection (6),

then, section 28 (other than subsection (7)(b) of that section) shall apply in relation to the agricultural property as it applies in relation to other property subject to the following modifications—

(i) in subsection (1) of that section, the reference to market value shall be construed as a reference to agricultural value,

(ii) where a deduction is to be made for any liability, costs or expenses in accordance with subsection (1) of that section only a proportion of such liability, costs or expenses is deducted and that proportion is the proportion that the agricultural value of the agricultural property bears to the market value of that property, and

(iii) where a deduction is to be made for any consideration under subsection (2) or (4)(b) of that section, only a proportion of such consideration is deducted and that proportion is the proportion that the agricultural value of the agricultural property bears to the market value of that property.

(3) For the purposes of subsection (2), if, in the administration of property subject to a disposition—

(a) property is appropriated in or towards the satisfaction of a benefit in respect of which a person is deemed to take a gift or an inheritance under the disposition, and

(b) the property so appropriated was subject to the disposition at the date of the gift or inheritance,

then the property is deemed to have been comprised in that gift or inheritance at the date of the gift or inheritance.

(4) For the purposes of subsection (2)(b)(i)—

(a) an individual is deemed to be beneficially entitled in possession to agricultural property that is subject to a discretionary trust under or in consequence of a disposition made by the individual, and

(b) where, prior to the date of the gift or inheritance, the disponer—

(i) disposed of agricultural property (other than crops, trees or underwood), and

(ii) any proceeds from such disposal were expended in directly replacing the agricultural property with other agricultural property within—

(I) one year of the disposal, or

(II) where the disposal arose as a consequence of a compulsory acquisition, within 6 years of the compulsory acquisition,

then that other agricultural property shall be treated as if it were the agricultural property referred to in subparagraph (i).

(5) The conditions referred to in subsection (2)(b)(ii) are that—

(a) the disponer—

(i) held a relevant qualification and used agricultural property (including the agricultural property comprised in the gift or inheritance) for the purposes of farming on a commercial basis and with a view to the realisation of profits from that agricultural property, or

(ii) spent at least 50 per cent of his or her normal working time using agricultural property (including the agricultural property comprised in the gift or inheritance) for the purposes of farming on a commercial basis and with a view to the realisation of profits from that agricultural property,

(b) the agricultural property comprised in the gift or inheritance was leased to an individual who satisfied the condition specified in subparagraph (i) or (ii) of paragraph (a), or

(c) the condition specified in subparagraph (i) or (ii) of paragraph (a) was satisfied in relation to part of the agricultural property comprised in the gift or inheritance and the condition specified in paragraph (b) was satisfied in relation to the remainder of the agricultural property comprised in the gift or inheritance.

(6) The conditions referred to in subsection (2)(d) are that the beneficiary—

(a) holds a relevant qualification (or becomes the holder of a relevant qualification within a period of 4 years commencing on the date of the gift or inheritance) and uses agricultural property (including the agricultural property comprised in the gift or inheritance) for the purposes of farming on a commercial basis and with a view to the realisation of profits from that agricultural property,

(b) spends at least 50 per cent of that individual’s normal working time using agricultural property (including the agricultural property comprised in the gift or inheritance) for the purposes of farming on a commercial basis and with a view to the realisation of profits from that agricultural property,

(c) leases the agricultural property comprised in the gift or inheritance to an individual who satisfies the condition specified in paragraph (a) or (b), or

(d) satisfies the condition specified in paragraph (a) or (b) in relation to part of the agricultural property comprised in the gift or inheritance and satisfies the condition specified in paragraph (c) in relation to the remainder of the agricultural property comprised in the gift or inheritance.

(7) (a) Where, within the period of not less than 6 years commencing on the valuation date of the gift or inheritance, any of the agricultural property (other than crops, trees or underwood) comprised in the gift or inheritance is disposed of, either in whole or in part (other than by way of a lease referred to in subsection (6)(c)) and any part of the proceeds from such disposal are not expended in acquiring other agricultural property—

(i) within one year of the disposal, or

(ii) where the disposal arises as a consequence of a compulsory acquisition, within 6 years of the compulsory acquisition,

then all or, as the case may be, part of the agricultural property shall, for the purposes of subsection (2), be treated as property comprised in the gift or inheritance which is not agricultural property and the taxable value of the gift or inheritance shall be determined in accordance with the formula set out in paragraph (b) without regard to the requirements of subsection (2)(c)) and tax shall be payable accordingly.

(b) For the purposes of paragraph (a)—

(i) the market value of agricultural property which is treated under paragraph (a) as not being agricultural property is determined by the formula—

V1 (N)/(V2)

where—

V1 is the market value of all of the agricultural property on the valuation date without regard to paragraph (a),

V2 is the market value of that agricultural property immediately before the disposal of all or, as the case may be, a part thereof, and

N is the amount of proceeds from the disposal of all the agricultural property or, as the case may be, a part thereof, that was not expended in acquiring other agricultural property,

and

(ii) the proceeds from a disposal—

(I) shall include an amount equal to the market value of the consideration (not being cash) received for the disposal, where full consideration is received for the disposal, or

(II) shall be an amount equal to the market value of the agricultural property immediately before the disposal, where less than full consideration is received for the disposal.

(c) If an arrangement is made, in the administration of property subject to a disposition, for the appropriation of property in or towards the satisfaction of a benefit under the disposition, such arrangement is deemed not to be a disposal for the purposes of paragraph (a).

(d) Subject to paragraph (e), where the proceeds referred to in paragraph (a) are expended in acquiring other agricultural property, then that other agricultural property shall, for the purposes of this section, be treated as if it were agricultural property comprised in the gift or inheritance.

(e) Where the proceeds referred to in paragraph (a) are expended in acquiring agricultural property which has been transferred by the beneficiary to his or her spouse or civil partner, such property shall not be treated as other agricultural property for the purposes of that paragraph.

(f) Paragraph (a) shall not apply where the beneficiary dies before the property is disposed of.

(8) Where, during the period of not less than 6 years commencing on the valuation date, the beneficiary no longer satisfies one of the conditions specified in subsection (6), all or, as the case may be, part of the agricultural property shall, for the purposes of subsection (2), otherwise than on the death of the beneficiary, be treated as property comprised in the gift or inheritance that is not agricultural property, and the taxable value of the gift or inheritance shall be determined accordingly and tax shall be payable accordingly.

(9) Where, pursuant to subsection (7) or (8), as the case may be, all or part of the property comprised in a gift or inheritance is to be treated as property that is not agricultural property then, by virtue of the return delivered in respect of the gift or inheritance being defective in a material respect, an additional return shall be delivered to the Commissioners, and any outstanding tax paid, in accordance with section 46(9).

(10) Subsection (2) shall apply in relation to agricultural property which consists of trees or underwood as if paragraphs (b), (c) and (d) were omitted from that subsection.

(11) Where solar panels are installed on no more than half the total area of land comprised in a gift or inheritance—

(a) the land shall be regarded as agricultural land for the purposes of the definition of ‘agricultural property’ in subsection (1),

(b) the conditions referred to in paragraphs (b)(ii) and (d) of subsection (2) shall be required to be satisfied only in respect of that part of the agricultural land comprised in the gift or inheritance on which solar panels are not installed, and

(c) a lease of the land on which the solar panels are installed shall not constitute a disposal of the land for the purposes of subsection (7)(a).

(12) Where, in the period of 6 years ending immediately prior to the date of the gift or inheritance comprising agricultural property, the disponer had become beneficially entitled in possession to that agricultural property on the death of his or her spouse or civil partner, then paragraph (b) of subsection (2) and subsections (4) and (5) shall, in relation to that agricultural property, apply as if a reference in those provisions to disponer were a reference to the spouse or civil partner concerned for that part of the period during which the disponer was not beneficially entitled in possession to the agricultural property concerned.

(13) This section shall apply to gifts and inheritances taken on or after the date on which this section comes into operation.

(14) For the purposes of this section, where a gift or inheritance is taken in the period of 6 years commencing on the date on which this section comes into operation, the period of 6 years referred to in subsection (2)(b) shall be treated as if it were the period commencing on the date on which this section comes into operation and ending on the date of the gift or inheritance.”.

(2) Subsection (1) shall come into operation on such day or days as the Minister for Finance shall appoint either generally or with reference to any particular purpose or provision and different days may be so appointed for different purposes or different provisions.

101. Amendments consequential on insertion of section 89A in Principal Act

101. (1) The Principal Act is amended—

(a) in section 28—

(i) in subsection (2), by the substitution of “section 89 or 89A, as the case may be” for “section 89”, and

(ii) in subsection (7)(b), by the substitution of “section 89(2)(ii) or (iii) or section 89A(2)(ii) or (iii), as the case may be,” for “section 89(2)(ii) or (iii)”,

(b) in section 46—

(i) in subsection (4), by the substitution of the following paragraph for paragraph (aa):

“(aa) the gift comprises or includes—

(i) agricultural property, within the meaning of section 89(1), in the case of a gift or inheritance taken prior to the date on which section 89A comes into operation,

(ii) agricultural property, within the meaning of subsection (1) of section 89A, in the case of a gift or inheritance taken on or after the date on which that section comes into operation, or

(iii) relevant business property, within the meaning of section 93(1),”,

and

(ii) in subsection (14), by the substitution of the following paragraph for paragraph (d):

“(d) the gift comprises or includes—

(i) agricultural property, within the meaning of section 89(1), in the case of a gift or inheritance taken prior to the date on which section 89A comes into operation,

(ii) agricultural property, within the meaning of subsection (1) of section 89A, in the case of a gift or inheritance taken on or after the date on which that section comes into operation, or

(iii) relevant business property, within the meaning of section 93(1), or”,

“(a) to the extent to which section 89(4)(a) applies, for the duration of the period from the valuation date to the date the agricultural value (within the meaning of section 89) ceases to be applicable,

(aa) to the extent to which section 89A(7)(a) applies, for the duration of the period from the valuation date to the date the agricultural value (within the meaning of section 89A) ceases to be applicable,”,

(d) in section 55—

(i) in subsection (1), by the substitution of the following definition for the definition of “agricultural property”:

“ ‘agricultural property’—

(a) in the case of a gift or inheritance taken prior to the date on which section 89A comes into operation, has the meaning assigned to it by section 89(1), or

(b) in the case of a gift or inheritance taken on or after the date on which section 89A comes into operation, has the meaning assigned to it by subsection (1) of that section;”, and

(ii) in subsection (2)(a)—

(I) by the insertion of “or subsection (7) of section 89A, as the case may be,” after “subsection (4) of section 89”, and

(II) by the insertion of “or subsection (2) of section 89A, as the case may be,” after “subsection (2) of section 89”,

(e) in section 89, by the insertion of the following subsection after subsection (7):

“(8) This section shall not apply to gifts or inheritances taken on or after the date on which section 89A comes into operation.”,

(f) in section 90(1), by the substitution of the following definition for the definition of “agricultural property”:

“ ‘agricultural property’—

(a) in the case of a gift or inheritance taken prior to the date on which section 89A comes into operation, has the meaning assigned to it by section 89(1), or

(b) in the case of a gift or inheritance taken on or after the date on which section 89A comes into operation, has the meaning assigned to it by subsection (1) of that section;”,

(g) in section 102, by the substitution of “section 89(2) or 89A(2), as the case may be,” for “section 89(2)”, and

(h) in section 102A—

(i) in subsection (1), by the substitution of the following definition for the definition of “agricultural property”:

“ ‘agricultural property’—

(a) in the case of a gift or inheritance taken prior to the date on which section 89A comes into operation, has the meaning assigned to it by section 89(1), or

(b) in the case of a gift or inheritance taken on or after the date on which section 89A comes into operation, has the meaning assigned to it by subsection (1) of that section;”, and

(ii) in subsection (2)(a), by the substitution of “section 89(2) or 89A(2), as the case may be,” for “section 89(2)”.

(2) The Taxes Consolidation Act 1997 is amended in section 654A(1), in paragraph (b) of the definition of “relevant provisions”, by the substitution of “sections 89 and 89A” for “section 89”.

(3) Subsections (1) and (2) shall come into operation on such day or days as the Minister for Finance shall appoint either generally or with reference to any particular purpose or provision and different days may be so appointed for different purposes or different provisions.

PART 6 Miscellaneous

102. **Interpretation (Part 6)**

102. In this Part, “Principal Act” means the Taxes Consolidation Act 1997.

103. Amendment of section 891J of Principal Act (return of certain information by Reporting Platform Operators)

103. Section 891J of the Principal Act is amended—

(a) in subsection (3)—

(i) in paragraph (a), by the substitution of “paragraph (c)” for “paragraph (b)”,

(ii) by the insertion of the following paragraphs after paragraph (d):

“(e) Subject to paragraph (f), where a platform operator, registered under paragraph (a) by virtue of subparagraph (ii) of the said paragraph (a), does not comply with its obligations under this section, or regulations made under this section, the Revenue Commissioners shall revoke the Platform Operator ID assigned to the platform operator concerned under paragraph (b).

(f) The Platform Operator ID shall not be revoked under paragraph (e) before—

(i) the Revenue Commissioners have issued 2 reminders in writing to the platform operator of the obligations imposed on that platform operator under this section, and

(ii) the expiration of 30 days from the date of the second such reminder referred to in subparagraph (i).

(g) Where a platform operator’s Platform Operator ID has been revoked under paragraph (e), the Platform Operator ID shall not be reinstated, or a new Platform Operator ID shall not be issued to the platform operator, until the platform operator demonstrates, by way of documentary evidence to the satisfaction of the Revenue Commissioners, and provides the Revenue Commissioners with a written assurance, that it will comply with the obligations imposed under this section and the regulations made under this section.”,

(b) in subsection (7)—

(i) by the substitution of the following paragraph for paragraph (b):

“(b) Where a reportable seller does not provide the relevant information to the reporting platform operator, the reporting platform operator shall on the day immediately following the expiration of the period referred to in paragraph (c)(ii) (referred to in paragraph (ba) as ‘the relevant date’) and until such time as the relevant information has been provided—

(i) either—

(I) subject to paragraph (ba), withhold payment of any consideration due to the reportable seller, or

(II) close the account of the reportable seller and prevent the reportable seller from reopening the account,

and

(ii) prevent the reportable seller from opening a new account with the reporting platform operator.”,

and

(ii) by the insertion of the following paragraph after paragraph (b) (amended by subparagraph (i)):

“(ba) Where a reporting platform operator has withheld payment of consideration due to a reportable seller pursuant to clause (I) of paragraph (b)(i), and the reportable seller does not provide the relevant information to the reporting platform operator within 24 months of the relevant date, the reporting platform operator shall pay to the reportable seller any consideration withheld in accordance with the said clause (I) and, until such time as the relevant information has been provided, take the actions specified in clause (II) of paragraph (b)(i) in respect of the reportable seller concerned.”,

(i) by the substitution of the following subparagraph for subparagraph (ii):

“(ii) closes the account of a reportable seller and prevents the reportable seller from reopening the account pursuant to paragraph (b)(i)(II) or (ba) of subsection (7),”,

(ii) in subparagraph (iii), by the substitution of “subsection (7)(b)(ii), or” for “subsection (7)(b)(i)(III),”,

(iii) in subparagraph (iv), by the substitution of “subsection (7)(ba)” for “subsection (7)(b)(i)(A)”, and

(iv) by the deletion of subparagraphs (v) and (vi),

and

(d) in subsection (16)(b)(ii), by the substitution of “paragraphs (b) and (ba) of subsection (7)” for “subsection (7)(b)”.

104. Amendment of section 891L of Principal Act (Implementation of Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU on administrative cooperation in the field of taxation in relation to joint audits)

104. Section 891L of the Principal Act is amended by the insertion of the following subsection after subsection (23):

“(23A) (a) Subject to paragraph (b), the rights and obligations of a Revenue officer participating in a joint audit in a Member State, other than the State, shall be determined in accordance with the laws of the Member State where the joint audit takes place.

(b) A Revenue officer participating in a joint audit referred to in paragraph (a) shall not exercise any powers that exceed the scope of the powers conferred on such an officer by the law of the State.”.

105. Amendment of section 991B of Principal Act (Covid-19: special warehousing and interest provisions)

105. Section 991B of the Principal Act is amended—

(a) by the deletion of subsection (7),

(b) by the substitution of the following subsection for subsection (8):

“(8) Where—

(a) this section applies to an employer,

(b) the employer complies with the employer’s obligations under the Acts,

(i) before 1 May 2024, engaged with the Collector-General regarding the employer’s Covid-19 liabilities with a view to entering into an agreement to pay those liabilities, and

(ii) entered into an agreement referred to in subparagraph (i), whether before or after 1 May 2024,

and

(d) the employer complies with the obligations of the employer under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the employer in respect of the employer’s Covid-19 liabilities during Period 1, Period 2 and Period 3.”,

and

“(10) Where an employer—

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the employer’s obligations under the Acts,

(b) is not an employer to whom subsection (8)(c) applies, or

(i) fails to comply with the employer’s obligations under the Acts, or

(ii) fails to comply with an obligation referred to in subsection (8)(d),

simple interest shall be paid by the employer to the Revenue Commissioners on any amount of the Covid-19 liabilities remaining unpaid on—

(I) in a case to which paragraph (a) or (c) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred, and

(II) in a case to which paragraph (b) applies, 1 May 2024,

and such interest shall be calculated from—

(A) in a case to which paragraph (a) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred,

(B) in a case to which paragraph (b) applies, the first day of Period 3, and

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0274 per cent.”.

106. Amendment of section 1080B of Principal Act (Covid-19: special warehousing and interest provisions (income tax))

106. Section 1080B of the Principal Act is amended—

(a) by the deletion of subsection (10),

(b) by the substitution of the following subsection for subsection (11):

“(11) Where—

(a) this section applies to a relevant person,

(b) the relevant person complies with the relevant person’s obligations under the Acts,

(i) before 1 May 2024, engaged with the Collector-General regarding the relevant person’s Covid-19 income tax with a view to entering into an agreement to pay that tax, and

(ii) entered into an agreement referred to in subparagraph (i), whether before or after 1 May 2024,

and

(d) the relevant person complies with the obligations of the relevant person under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the relevant person in respect of the relevant person’s Covid-19 income tax during Period 1, Period 2 and Period 3.”,

and

“(12) Where a relevant person—

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the relevant person’s obligations under the Acts,

(b) is not a relevant person to whom subsection (11)(c) applies, or

(i) fails to comply with the relevant person’s obligations under the Acts, or

(ii) fails to comply with an obligation referred to in subsection (11)(d),

simple interest shall be paid by the relevant person to the Revenue Commissioners on any amount of the Covid-19 income tax remaining unpaid on—

(I) in a case to which paragraph (a) or (c) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred, and

(II) in a case to which paragraph (b) applies, 1 May 2024,

and such interest shall be calculated from—

(A) in a case to which paragraph (a) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred,

(B) in a case to which paragraph (b) applies, the first day of Period 3, and

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0219 per cent.”.

107. Amendment of section 28C of Emergency Measures in the Public Interest (Covid-19) Act 2020 (Covid-19: special warehousing and interest (relevant tax due under section 28(9)))

107. Section 28C of the Emergency Measures in the Public Interest (Covid-19) Act 2020 is amended—

(a) by the deletion of subsection (6),

(b) by the substitution of the following subsection for subsection (7):

“(7) Where—

(a) this section applies to an employer,

(b) the employer complies with the employer’s obligations under the Acts,

(i) before 1 May 2024, engaged with the Collector-General regarding the employer’s liability in respect of Covid-19 relevant tax with a view to entering into an agreement to pay that liability, and

(ii) entered into an agreement referred to in subparagraph (i), whether before or after 1 May 2024,

and

(d) the employer complies with the obligations of the employer under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the employer in relation to the employer’s liability in respect of Covid-19 relevant tax during Period 1, Period 2 and Period 3.”,

and

“(8) Where an employer—

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the employer’s obligations under the Acts,

(b) is not an employer to whom subsection (7)(c) applies, or

(i) fails to comply with the employer’s obligations under the Acts, or

(ii) fails to comply with an obligation referred to in subsection (7)(d),

simple interest shall be paid by the employer to the Revenue Commissioners in relation to any amount of the Covid-19 relevant tax remaining unpaid on—

(I) in a case to which paragraph (a) or (c) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred, and

(II) in a case to which paragraph (b) applies, 1 May 2024,

and such interest shall be calculated from—

(A) in a case to which paragraph (a) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred,

(B) in a case to which paragraph (b) applies, the first day of Period 3, and

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0219 per cent.”.

108. Amendment of section 28D of Emergency Measures in the Public Interest (Covid-19) Act 2020 (Covid-19: special warehousing and interest (relevant tax due under section 28B(11)))

108. Section 28D of the Emergency Measures in the Public Interest (Covid-19) Act 2020 is amended—

(a) by the deletion of subsection (6),

(b) by the substitution of the following subsection for subsection (7):

“(7) Where—

(a) this section applies to an employer,

(b) the employer complies with the employer’s obligations under the Acts,

(i) before 1 May 2024, engaged with the Collector-General regarding the employer’s liability in respect of Covid-19 relevant tax with a view to entering into an agreement to pay that liability, and

(ii) entered into an agreement referred to in subparagraph (i), whether before or after 1 May 2024,

and

(d) the employer complies with the obligations of the employer under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the employer in relation to the employer’s liability in respect of Covid-19 relevant tax during Period 1, Period 2 and Period 3.”,

and

“(8) Where an employer—

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the employer’s obligations under the Acts,

(b) is not an employer to whom subsection (7)(c) applies, or

(i) fails to comply with the employer’s obligations under the Acts, or

(ii) fails to comply with an obligation referred to in subsection (7)(d),

simple interest shall be paid by the employer to the Revenue Commissioners in relation to any amount of the Covid-19 relevant tax remaining unpaid on—

(I) in a case to which paragraph (a) or (c) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred, and

(II) in a case to which paragraph (b) applies, 1 May 2024,

and such interest shall be calculated from—

(A) in a case to which paragraph (a) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred,

(B) in a case to which paragraph (b) applies, the first day of Period 3, and

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0219 per cent.”.

109. Amendment of section 114B of Value-Added Tax Consolidation Act 2010 (Covid-19: special warehousing and interest provisions)

109. Section 114B of the Value-Added Tax Consolidation Act 2010 is amended—

(a) by the deletion of subsection (7),

(b) by the substitution of the following subsection for subsection (8):

“(8) Where—

(a) this section applies to an accountable person,

(b) the accountable person complies with the accountable person’s obligations under the Acts,

(i) before 1 May 2024, engaged with the Collector-General regarding the accountable person’s Covid-19 liabilities with a view to entering into an agreement to pay those liabilities, and

(ii) entered into an agreement referred to in subparagraph (i), whether before or after 1 May 2024,

and

(d) the accountable person complies with the obligations of the accountable person under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the accountable person in respect of the accountable person’s Covid-19 liabilities during Period 1, Period 2 and Period 3.”,

and

“(10) Where an accountable person—

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the accountable person’s obligations under the Acts,

(b) is not an accountable person to whom subsection (8)(c) applies, or

(i) fails to comply with the accountable person’s obligations under the Acts, or

(ii) fails to comply with an obligation referred to in subsection (8)(d),

simple interest shall be paid by the accountable person to the Revenue Commissioners on any amount of the Covid-19 liabilities remaining unpaid on—

(I) in a case to which paragraph (a) or (c) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred, and

(II) in a case to which paragraph (b) applies, 1 May 2024,

and such interest shall be calculated from—

(A) in a case to which paragraph (a) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred,

(B) in a case to which paragraph (b) applies, the first day of Period 3, and

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0274 per cent.”.

110. Section 17C of the Social Welfare Consolidation Act 2005 is amended—

(a) by the deletion of subsection (7),

(b) by the substitution of the following subsection for subsection (8):

“(8) Where—

(a) this section applies to an employer,

(b) the employer complies with the employer’s obligations under section 17A,

(i) before 1 May 2024, engaged with the Collector-General regarding the employer’s Covid-19 liabilities with a view to entering into an agreement to pay those liabilities, and

(ii) entered into an agreement referred to in subparagraph (i), whether before or after 1 May 2024,

and

(d) the employer complies with the obligations of the employer under the agreement entered into as referred to in paragraph (c)(ii),

no interest shall be due and payable by the employer in respect of the employer’s Covid-19 liabilities during Period 1, Period 2 and Period 3.”,

and

“(10) Where an employer—

(a) at any time during the period beginning on the first day of Period 1 and ending on 30 April 2024 fails to comply with the employer’s obligations under section 17A,

(b) is not an employer to whom subsection (8)(c) applies, or

(i) fails to comply with the employer’s obligations under section 17A, or

(ii) fails to comply with an obligation referred to in subsection (8)(d),

simple interest shall be paid by the employer to the Revenue Commissioners on any amount of the Covid-19 liabilities remaining unpaid on—

(I) in a case to which paragraph (a) or (c) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred, and

(II) in a case to which paragraph (b) applies, 1 May 2024,

and such interest shall be calculated from—

(A) in a case to which paragraph (a) applies, the date on which the event resulting in failure to comply with the obligation concerned occurred,

(B) in a case to which paragraph (b) applies, the first day of Period 3, and

until payment of the amount for any day or part of a day during which that amount remains unpaid, at a rate of 0.0274 per cent.”.

111. Repayment of tax in case of ceased company: double taxation relief

111. Chapter 1 of Part 35 of the Principal Act is amended by the insertion of the following section after section 826A:

“826B. (1) In this section—

‘chargeable period’ has the meaning assigned to it by section 321;

‘controlling interest’ has the meaning assigned to it by section 111A;

‘correlative adjustment’ means an adjustment of profits under the terms of an arrangement having the force of law by virtue of subsection (1) or (1B), as the case may be, of section 826;

‘effective 90 per cent subsidiary’ shall be construed in accordance with subsection (2);

‘mutual agreement reached’ means an agreement reached between the competent authority of the State and a competent authority of another jurisdiction in accordance with a mutual agreement procedure under an arrangement having the force of law by virtue of subsection (1) or (1B), as the case may be, of section 826;

‘ultimate parent entity’ means a company that owns, directly or indirectly, a controlling interest in any other company and that is not owned, directly or indirectly, by another company with a controlling interest in it;

‘valid application’ shall be construed in accordance with subsection (4).

(2) (a) Subject to paragraphs (b) and (c), for the purposes of this section, a company shall be an effective 90 per cent subsidiary of another company (in this paragraph referred to as ‘the parent company’) at any time if at that time—

(i) the company is a 90 per cent subsidiary (within the meaning of section 9 (as modified by paragraph (b))) of the parent company,

(ii) the parent company is beneficially entitled to not less than 90 per cent of any profits available for distribution to equity holders of the company, and

(iii) the parent company would be beneficially entitled to not less than 90 per cent of the assets of the company available for distribution to its equity holders on a winding up.

(b) For the purposes of subparagraph (i) of paragraph (a), section 9 shall apply as if, in subsection (1)(c) of that section, ‘directly or indirectly’ were substituted for ‘directly’.

(c) For the purposes of subparagraphs (ii) and (iii) of paragraph (a), sections 413, 414, 415 and 418 shall, with any necessary modifications but without regard to section 411(1)(c) in so far as it relates to those sections, apply to the determination of the percentage of those profits or assets, as the case may be, to which a company is beneficially entitled as those provisions apply to the determination for the purposes of Chapter 5 of Part 12 of the percentage of any such profits or assets, as the case may be, to which a company is so entitled.

(3) Subject to subsections (4) to (8), where—

(a) a company (in this section referred to as ‘the ceased company’)—

(i) has ceased to exist,

(ii) would be entitled to a repayment of tax for a chargeable period, but for the fact that the company ceased to exist, and the repayment arises from—

(I) a correlative adjustment, or

(II) a mutual agreement reached,

(iii) is not a transferor company for the purposes of section 865(10), and

(iv) immediately prior to it ceasing to exist, was an effective 90 per cent subsidiary of a company that was an ultimate parent entity at that time (in this section referred to as a ‘group parent company’),

and

(b) another company (in this section referred to as a ‘group repayment company’) is resident in the State and the group repayment company is—

(i) the group parent company,

(ii) an effective 90 per cent subsidiary of the group parent company, or

(iii) where the group parent company—

(I) has ceased to exist, and

(II) immediately prior to it ceasing to exist, was an effective 90 per cent subsidiary of a company that was an ultimate parent entity at that time (in this section referred to as a ‘successor group parent company’),

the successor group parent company or an effective 90 per cent subsidiary of the successor group parent company,

then, the group parent company, or the successor group parent company where paragraph (b)(iii) applies, may submit a valid application to the Revenue Commissioners to have sections 864 and 865 apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company, were, as appropriate—

(I) a thing done pursuant to sections 864 and 865, or

(II) a thing required to be done pursuant to sections 864 and 865,

by or for a group repayment company, nominated in writing by the group parent company, or the successor group parent company where paragraph (b)(iii) applies.

(4) For the purposes of this section, an application submitted by the group parent company or the successor group parent company, as the case may be, shall be regarded as a valid application where all the information which the Revenue Commissioners may reasonably require to enable them to determine whether the conditions provided for in paragraphs (a) and (b) of subsection (3) have been satisfied is contained in the application.

(5) Where, following receipt of a valid application, the Revenue Commissioners are of the opinion that in order to give effect to the correlative adjustment or the mutual agreement reached, it would be appropriate for sections 864 and 865 to apply, in respect of the chargeable period, as if any thing done pursuant to sections 864 and 865 or required to be done pursuant to sections 864 and 865 by or for the ceased company were, as appropriate—

(a) a thing done pursuant to sections 864 and 865, or

(b) a thing required to be done pursuant to sections 864 and 865,

by or for the group repayment company, then—

(i) sections 864 and 865 shall apply on that basis,

(ii) the Revenue Commissioners shall notify—

(I) the group parent company or the successor group parent company, as the case may be, and

(II) where it is a different company, the group repayment company,

that sections 864 and 865 shall apply on that basis, and

(iii) the ceased company shall not be entitled to a repayment of tax for the chargeable period arising from the correlative adjustment or the mutual agreement reached, as the case may be.

(6) The amount of any repayment of tax or part repayment of tax to be made to a group repayment company under this section shall not exceed the total amount that would have been made to a ceased company if it had not ceased to exist.

(7) The Revenue Commissioners may nominate any of their officers to perform any acts and discharge any functions authorised by this section to be performed or discharged by the Revenue Commissioners, and references in this section to the Revenue Commissioners shall with any necessary modifications be construed as including references to an officer so nominated.

(8) This section shall not apply where it would be reasonable to consider that the main purpose, or one of the main purposes, of the ceased company ceasing to exist is to secure a repayment of tax or part repayment of tax under this section.

(9) This section shall only apply where a repayment of tax arises in relation to—

(a) a correlative adjustment in respect of which a determination has been made under section 864, or

(b) a mutual agreement reached,

on or after the date of the passing of the Finance Act 2024.”.

112. Amendment of Schedule 24A to Principal Act (arrangements made by the Government with the government of any territory outside the State in relation to affording relief from double taxation and exchanging information in relation to tax)

112. Schedule 24A to the Principal Act is amended—

(a) in Part 1, by the insertion of the following paragraph after paragraph 30:

“30A. The Double Taxation Relief (Taxes on Income) (Sultanate of Oman) Order 2024 (S.I. No. 485 of 2024).”,

and

(b) in Part 3, by the substitution of the following paragraph for paragraph 7:

“7. The Exchange of Information Relating to Tax Matters and Double Taxation Relief (Taxes on Income) (Jersey) Order 2010 (S.I. No. 28 of 2010) and the Double Taxation Relief (Taxes on Income) (Jersey) Order 2024 (S.I. No. 484 of 2024).”.

113. Amount of vacant homes tax

113. The Principal Act is amended by the substitution of the following section for section 653AP:

“653AP. (1) The amount of vacant homes tax to be charged in respect of a residential property for the chargeable period commencing on 1 November 2022 shall be the amount represented by ‘A’ in the formula—

A = B 3

where ‘B’ is the amount of local property tax payable in respect of the residential property in relation to the liability date of 1 November 2022 calculated in accordance with section 17 of the Act of 2012 (before any adjustment is made in accordance with section 20 of that Act).

(2) The amount of vacant homes tax to be charged in respect of a residential property for the chargeable period commencing on 1 November 2023 shall be the amount represented by ‘A’ in the formula—

A = B 5

where ‘B’ is the amount of local property tax payable in respect of the residential property in relation to the liability date of 1 November 2023 calculated in accordance with section 17 of the Act of 2012 (before any adjustment is made in accordance with section 20 of that Act).

(3) The amount of vacant homes tax to be charged in respect of a residential property for the chargeable period commencing on 1 November 2024 and for each subsequent chargeable period shall be the amount represented by ‘A’ in the formula—

A = B 7

where ‘B’ is the amount of local property tax payable in respect of the residential property in relation to the liability date falling in the year in which the chargeable period commences calculated in accordance with section 17 of the Act of 2012 (before any adjustment is made in accordance with section 20 of that Act).”.

114. Residential zoned land tax

114. Part 22A of the Principal Act is amended—

(a) in section 653A(2), by the substitution of “other than in the definition of ‘planning permission period’ in subsection (1) and in the definition of ‘relevant appeal’ in section 653AF(1)” for “other than in subsection (1) and section 653AF(1)(a)”,

(b) in section 653I—

(i) in subsection (1)—

(I) in paragraph (b), by the substitution of “section 653F,” for “section 653F, or”,

(II) in paragraph (c), by the substitution of “section 653M(1), or” for “section 653M(1),”,

(III) by the insertion of the following paragraph after paragraph (c):

“(d) during the period beginning on 1 February 2025 and ending on 1 April 2025, to a local authority on a revised map for the year 2025 published in accordance with section 653M(1),”,

and

(IV) by the substitution of “requesting a change to the zoning of lands included in the draft map, supplemental map or revised map, as the case may be.” for “requesting a change to the zoning of lands included in the draft map or supplemental map, as the case may be.”,

(ii) by the insertion of the following subsection after subsection (3):

“(3A) (a) In a case in which a submission is made under subsection (1)(d), the local authority shall acknowledge receipt of the submission to the person who made that submission, in writing, not later than 30 April 2025.

(b) The acknowledgement referred to in paragraph (a) shall include—

(i) confirmation by the local authority as to whether, as at the date on which the acknowledgement issues, in respect of the lands, or any part of the lands, the subject of the submission—

(I) planning permission has been granted in respect of development of the land which consists in whole or in part of residential development, and the planning permission period has not expired (in this section and section 653IA referred to as an ‘extant planning permission for residential development’), or

(II) a planning application has been made in respect of the development of the land which consists in whole or in part of residential development, but, in relation to such planning application—

(A) the local authority has not made a decision or, in a case where the planning application has been made to An Bord Pleanála under the Planning and Development (Housing) and Residential Tenancies Act 2016, An Bord Pleanála has not made a decision,

(B) in a case where the decision of the local authority is the subject of an appeal to An Bord Pleanála, the appeal is not determined, or

(C) in a case where a decision of the local authority or An Bord Pleanála, as the case may be, is the subject of a judicial review, the judicial review is not determined,

(in this section and section 653IA referred to as a ‘current planning application for residential development’),

and

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Finance Act 2024

72. Amendment of section 67 of Finance Act 2002 (betting duty)

73. Amendment of section 67A of Finance Act 2002 (application of betting duty to remote bookmakers)

74. Amendment of section 68A of Finance Act 2002

75. Amendment of Chapter 1 of Part 2 of Finance Act 2002 (licence duty)

76. Amendment of section 132 of Finance Act 1992 (charge of excise duty)

PART 3 Value-Added Tax

77. Interpretation (Part 3)

78. Amendment of section 2 of Principal Act

79. Amendment of section 46 of Principal Act (rates of tax)

80. Amendment of section 59 of Principal Act (deduction for tax borne or paid)

81. Amendment of section 60 of Principal Act (general limits on deductibility)

82. Amendment of section 76 of Principal Act (returns and remittances)

83. Amendment of section 86 of Principal Act (special provisions for tax invoiced by flat-rate farmers)

84. Amendment of section 115 of Principal Act (penalties generally)

85. Amendment of paragraph 6(2) of Schedule 1 to Principal Act (other exempted activities)

86. Amendment of paragraphs 4 and 6 of Schedule 2 to Principal Act (zero-rated goods and services)

87. Amendment of Schedule 2 to Principal Act (zero-rated goods and services)

88. Amendment of Schedule 3 to Principal Act (goods and services chargeable at the reduced rate)

PART 4 Stamp Duties

89. Interpretation (Part 4)

90. Amendment to stamp duty rates in respect of residential property

91. Amendment of section 31E of Principal Act (stamp duty on certain acquisitions of residential property)

92. Farming reliefs

93. Stamp duties modernisation

94. Provisions in relation to repayment of stamp duty

95. Banking levies modernisation

96. Amendment of section 126AB of Principal Act (further levy on certain financial institutions)

PART 5 Capital Acquisitions Tax

97. Interpretation (Part 5)

98. Amendment of section 46 of Principal Act (delivery of returns)

99. Amendment of Schedule 2 to Principal Act (computation of tax)

100. Further provisions relating to agricultural property

101. Amendments consequential on insertion of section 89A in Principal Act

PART 6 Miscellaneous

102. Interpretation (Part 6)

103. Amendment of section 891J of Principal Act (return of certain information by Reporting Platform Operators)

104. Amendment of section 891L of Principal Act (Implementation of Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU on administrative cooperation in the field of taxation in relation to joint audits)

105. Amendment of section 991B of Principal Act (Covid-19: special warehousing and interest provisions)

106. Amendment of section 1080B of Principal Act (Covid-19: special warehousing and interest provisions (income tax))

107. Amendment of section 28C of Emergency Measures in the Public Interest (Covid-19) Act 2020 (Covid-19: special warehousing and interest (relevant tax due under section 28(9)))

108. Amendment of section 28D of Emergency Measures in the Public Interest (Covid-19) Act 2020 (Covid-19: special warehousing and interest (relevant tax due under section 28B(11)))

109. Amendment of section 114B of Value-Added Tax Consolidation Act 2010 (Covid-19: special warehousing and interest provisions)

110. Amendment of section 17C of Social Welfare Consolidation Act 2005 (Covid-19: special warehousing and interest provisions for contributions)

111. Repayment of tax in case of ceased company: double taxation relief

112. Amendment of Schedule 24A to Principal Act (arrangements made by the Government with the government of any territory outside the State in relation to affording relief from double taxation and exchanging information in relation to tax)

113. Amount of vacant homes tax

114. Residential zoned land tax

77. **Interpretation (Part 3)**

89. **Interpretation (Part 4)**

97. **Interpretation (Part 5)**

102. **Interpretation (Part 6)**