Consultative Committee of Accountancy Bodies Ireland

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Feedback provided on various sections of Finance Bill 2025.

Requested that the Case 1 carve-out included in some of the Tax and Duty Manuals on the tax treatment of stock lending/Sale and Repurchase (repo) Transactions could also be extended to Section 110 companies.

Requested a legislative change to allow companies to opt out of the Knowledge Development Box regime. In the absence of this change

we requested that guidance is updated to allow companies to submit a nil claim on the Corporation Tax return where a company chooses not to make a claim.

Requested confirmation from Revenue that Directors emoluments paid after the end of the year could be included in an amended payroll submission for the final month of the previous year.

Requested Revenue to clarify the meaning of “associated entities” in the context of partnerships and the Outbound Payment Defensive Measures. We raised a point in how the definition is discussed differently in other guidance materials.

Requested Revenue to design a relevant tax return for Investment Limited Partnerships (ILP) to complete and file.

We raised our concerns regarding the application of withholding tax and exclusion of entities from the participation exemption for certain foreign distributions where a partial or nominal refund of tax applied as announced in Finance Bill 2025.

Requested Revenue to provide guidance on the treatment of loss-making branches and the double deduction rules in the context of non-trapped loss situations.

Guidance on the Key Employee Engagement Programme (KEEP) scheme to be updated to confirm that relevant limits apply only at the time of option grant.