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FINANCE BILL 2014 LIST OF ITEMS PART 1 MEASURES ANNOUNCED IN THE BUDGET PART 2 FURTHER MEASURES INCLUDED IN THE BILL

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FINANCE BILL 2014

LIST OF ITEMS

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EASURES ANNOUNCED IN THE

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PART 1 - MEASURES ANNOUNCED IN THE BUDGET ... 5

INCOME TAX ... 5

SECTION 2&3-INCOME TAX AND USC ... 5

OTHER INCOME TAX ... 5

SECTION 13-SPECIAL ASSIGNEE RELIEF PROGRAMME (SARP) ... 5

SECTION 14-FOREIGN EARNINGS DEDUCTION (FED) ... 5

SECTION 24-EMPLOYMENT AND INVESTMENT INCENTIVE (EII) AND SEED CAPITAL SCHEME (SCS) ... 5

SECTION 5-ARTISTS’EXEMPTION ... 6

SECTION 8-RENT-A-ROOM SCHEME ... 6

SECTION 11-HOME RENOVATION INCENTIVE ... 6

CAPITAL GAINS TAX ... 6

SECTION 27-WINDFALL TAX PROVISIONS ... 6

SECTION 44-CAPITAL GAINS TAX (CGT) RETIREMENT RELIEF ... 6

SECTION 43-CAPITAL GAINS TAX (CGT) FARM RESTRUCTURING RELIEF ... 6

CAPITAL ACQUISITIONS TAX ... 7

SECTION 74-CAPITAL ACQUISITIONS TAX (CAT) AGRICULTURAL RELIEF ... 7

DIRT ... 7

SECTION 20-DIRT FOR FIRST TIME HOUSE BUYERS ... 7

AGRI TAXATION ... 7

SECTION 18- AMENDMENTS TO LAND LEASING AND INCOME AVERAGING TAX PROVISIONS: ... 7

SECTION 66-AGRICULTURAL LEASES ... 7

SECTION 69-CONSANGUINITY RELIEF ... 7

CORPORATION TAX ... 7

SECTION 38-COMPANY RESIDENCE ... 7

SECTION 35-INTANGIBLE ASSETS ... 8

SECTION 23-RESEARCH AND DEVELOPMENT (R&D)TAX CREDIT ... 8

SECTION 34-3YEAR CORPORATION TAX RELIEF FOR START UP COMPANIES ... 8

SECTION 33-ACCELERATED CAPITAL ALLOWANCES FOR COMPANIES INVESTMENT IN ENERGY EFFICIENT EQUIPMENT ... 8

INDIRECT TAXES ... 8

VALUE-ADDED TAX ... 8

SECTION 60-FARMERS’FLAT-RATE ADDITION ... 8

EXCISE ... 9

SECTION 53-TOBACCO PRODUCTS TAX ... 9

SECTION 55-VEHICLE REGISTRATION TAX (VRT) ... 9

SECTION 52-ALCOHOL PRODUCTS TAX ... 9

SECTION 48-DEFERRAL OF EXCISE PAYMENT ON MINERAL OIL ... 9

SECTION 49-NATURAL GAS AS A TRANSPORT FUEL ... 9

PART 2 - FURTHER MEASURES INCLUDED IN THE BILL ... 10

INCOME TAX ... 10

SECTION 9-TRUSTS FOR PERMANENTLY INCAPACITATED INDIVIDUALS ... 10

SECTION 6-MORTGAGE INTEREST RELIEF ... 10

SECTION 12-DUAL ABODE ALLOWANCE ... 10

OTHER INCOME TAX ... 10

SECTION 16-TAX RELIEF ON DONATIONS TO APPROVED BODIES ... 10

SECTION 4-TAX TREATMENT OF DIRECTORS OF COMPANIES AND EMPLOYEES GRANTED RIGHTS TO ACQUIRE SHARES OR OTHER ASSETS ... 10

SECTION 29-INCENTIVES FOR CERTAIN AVIATION SERVICES FACILITIES... 10

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SECTION 22-SECURITIES ISSUED BY THE COMPANY TO BE ESTABLISHED UNDER SECTION 5 OF THE GAS

REGULATION ACT 2013 ... 10

CAPITAL GAINS TAX ... 11

SECTION 40-TEMPORARY NON-RESIDENTS ... 11

SECTION 41-WORKS OF ART AS “WASTING ASSETS” ... 11

SECTION 39-TIME LIMITS FOR MAKING AN ASSESSMENT TO CLAW BACK CERTAIN CGT RELIEFS ... 11

SECTION 46-CGT ENTREPRENEUR RELIEF ... 11

SECTION 45-SINGLE FARM PAYMENT ENTITLEMENTS ... 11

SECTION 42-VODAFONE PLC –TREATMENT OF RETURNS OF VALUE ... 11

CAPITAL ACQUISITIONS TAX ... 12

SECTION 75-CAT BUSINESS RELIEF ... 12

SECTION 72-DISCRETIONARY TRUSTS SET UP FOR CHARITABLE PURPOSES ... 12

SECTION 73-CERTAIN PAYMENTS MADE OR PROVIDED FOR BY PARENTS ... 12

STAMP DUTY ... 12

SECTION 70-YOUNG TRAINED FARMER RELIEF ... 12

SECTION 65&67-NATIONAL TREASURY MANAGEMENT AGENCY ... 12

SECTION 68-BANK LEVY ... 13

SECTION 77-DOMICILE LEVY PENALTIES ... 13

SECTION 19-SOCIAL INSURANCE FUND –TAX ON INTEREST ... 13

PENSION TAXATION ... 13

SECTION 17-APPROVED RETIREMENT FUNDS (ARFS) AND “VESTED”PERSONAL RETIREMENT SAVINGS ACCOUNTS (PRSAS). ... 13

SECTION 17-PENSION CONTRIBUTIONS BY CERTAIN FIXED-TERM CONTRACT EMPLOYEES ... 13

SECTION 17-STANDARD FUND THRESHOLD (SFT) AND PENSION ADJUSTMENT ORDERS (PAOS) ... 13

SECTION 17-IMPUTED DISTRIBUTION ARRANGEMENTS FOR ARFS AND ACCESS TO APPROVED MINIMUM RETIREMENT FUNDS (AMRFS) ... 13

LIVING CITY INITIATIVE ... 14

SECTION 28-LIVING CITY INITIATIVE ... 14

FILM RELIEF ... 14

SECTION 21&82-FILM RELIEF ... 14

CORPORATION TAX ... 14

SECTION 25-REAL ESTATE INVESTMENT TRUST (REIT)COMPANIES ... 14

SECTION 26-TAX TREATMENT OF RELEVANT ALTERNATIVE INVESTMENT FUNDS (AIFS) ... 14

SECTION 31-SHORT-LIFE ASSET OPERATING LESSORS ... 14

SECTIONS 32,36,37&35-OTHER CORPORATION TAX CHANGES ... 15

TAX ADMINISTRATION AND REVENUE POWERS ... 15

SECTION 79(AND SCHEDULE 1)-GENERAL ANTI-AVOIDANCE LEGISLATION ... 15

SECTION 80(AND SCHEDULE 2)-MANDATORY DISCLOSURE ... 16

SECTION 87-ELECTRONIC TAX CLEARANCE... 16

SECTION 85-SECURITY REQUIRED BY COLLECTOR-GENERAL... 16

SECTION 30-TAX EXEMPTION OF CERTAIN INCOME ... 17

SECTION 10-MANUFACTURED LOSSES ... 17

SECTION 84-DEFINITION OF “FINANCIAL INSTITUTION” FOR THIRD PARTY REPORTING OF PAYMENTS ... 17

SECTION 81-FINANCIAL INFORMATION REQUIRED FOR CTRETURN ... 17

SECTION 7-PROFESSIONAL SERVICES WITHHOLDING TAX (PSWT) ... 17

SECTION 86-NON-APPLICATION OF SURCHARGE ... 17

SECTION 15-RELEVANT CONTRACTS TAX PENALTIES ... 17

SECTION 78-DEFINITION OF “CHARGEABLE PERSON” ... 18

SECTION 83-RECORD KEEPING BY PERSONAL REPRESENTATIVES ... 18

INTERNATIONAL TAX AGREEMENTS ... 18

SECTION 88-RATIFICATION OF DOUBLE TAX AGREEMENTS (DTAS) WITH THAILAND AND BOTSWANA, AND PROTOCOLS TO THE DTAS WITH BELGIUM,LUXEMBOURG, AND DENMARK. ... 18

INDIRECT TAXES ... 18

VALUE-ADDED TAX ... 18

SECTION 59-RETENTION OF RECORDS ... 18

SECTION 61-ANTI-AVOIDANCE MEASURE:ISSUE OF VATDOCUMENTS ... 18

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SECTION 63-FOSTERING ... 19

SECTION 63-DEFINED CONTRIBUTION PENSION FUNDS -ATPPENSIONSERVICES ECJJUDGEMENT... 19

SECTION 63-MEMBER-OWNED GOLF CLUB FEES –BRIDPORT ECJCASE JUDGEMENT ... 19

SECTION 63-HERBAL TEA ... 19

EXCISE ... 19

SECTION 51-MINOR TECHNICAL AMENDMENTS ... 19

SECTION 56&57-VEHICLE REGISTRATION TAX ... 19

SECTION 47-POWER OF OFFICERS (BETTING DUTY) ... 20

SECTION 50-MINERAL OIL TRADERS LICENCE ... 20

SECTION 54-DISABLED DRIVERS AND DISABLED PASSENGERS (TAX CONCESSIONS)SCHEME ... 20

MINOR TECHNICAL AMENDMENTS ... 20

SECTION 89-MINOR TECHNICAL AMENDMENTS ... 20

NON TAX ITEM ... 20

SECTION 91-CAPITAL SERVICES REDEMPTION ACCOUNT (CSRA) ... 20

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INCOME TAX

SECTION 2&3-INCOME TAX AND USC

The Income Tax changes announced on Budget day are dealt with in Section 3 of the Bill, while section 2 deals with the announced USC changes.

OTHER INCOME TAX

SECTION 13-SPECIAL ASSIGNEE RELIEF PROGRAMME (SARP)

SARP is being amended and extended for a further three years until the end of 2017. The cap on qualifying salary is being lifted. The requirement to be tax resident In Ireland and not resident elsewhere is being removed such that the only requirement will be tax residence in Ireland. The performance of work-related duties outside of the State will be permitted and the requirement to have been employed abroad by the same employer will be reduced from 12 months to 6 months.

SECTION 14-FOREIGN EARNINGS DEDUCTION (FED)

The FED is being amended and extended for a further three years until the end of 2017. The number of qualifying countries is being increased to include Japan, Singapore, South Korea, Saudi Arabia, UAE, Qatar, Bahrain, Oman, Kuwait, Indonesia, Vietnam, Thailand, Chile, Mexico and Malaysia in line with the Government’s strategy on Trade, Tourism and Investment. The overall number of days required to be working abroad is being reduced from 60 to 40 and travel time to a qualifying country, between qualifying countries and return travelling time to Ireland will be deemed to be time spent in a qualifying country. The minimum stay abroad is being reduced to 3 days and if an employee is engaging in a multi-state trip, the 3 day minimum stay requirement can be accumulated among qualifying countries.

SECTION 24 - EMPLOYMENT AND INVESTMENT INCENTIVE (EII) AND SEED CAPITAL SCHEME

(SCS)

The EII and SCS are being amended. In relation to the EII, the minimum holding period is being increased to four years and the scheme is being extended to include medium-sized companies in non-assisted areas. The company annual limit is being increased from €2.5m to €5m and the lifetime limit from €10m to €15m. Internationally traded financial services, providing they are certified by Enterprise Ireland may avail of the scheme and the inclusion of hotels, guest-houses and self-catering accommodation is being extended for a further three years. In addition, the operating or managing of nursing homes will be included for a period of three years.

These changes are subject to State Aid approval.

The amendments to the SCS will see the scheme re-branded as “Start-up Refunds for Entrepreneurs” (SURE).

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SECTION 5-ARTISTS’EXEMPTION

Currently under the Artists’ Exemption, the first €40,000 per annum of profits or gains earned by writers, composers, visual artists and sculptors from the sale of their work is exempt from income tax in Ireland in certain circumstances. This annual maximum threshold is being increased by €10,000 to €50,000 with effect from 1 January 2015.

The Exemption is also being extended to non-resident artists (i.e. to individuals who are resident or ordinarily resident in another Member State or in another EEA State) to address concerns raised by the EU Commission that the scheme may constitutes a restriction to freedom of establishment, as guaranteed by the TFEU and the EEA Agreement.

SECTION 8-RENT-A-ROOM SCHEME

The current exemption from Income Tax, PRSI and USC on rent received where a homeowner rents out a room or rooms in his or her principal private residence and the rent received does not exceed €10,000 per year is being increased to €12,000.

SECTION 11-HOME RENOVATION INCENTIVE

The Home Renovation Incentive is being extended to include rental properties whose owners are liable to income tax. The current minimum qualifying spend of €5,000 and maximum qualifying spend of €30,000 will apply per property or unit within a property. The HRI will be available to landlords for work carried out from Budget night until the end of 2015.

CAPITAL GAINS TAX

SECTION 27-WINDFALL TAX PROVISIONS

Windfall tax provisions introduced in 2009 which apply an 80% rate of tax to certain profits or gains from land disposals or land development, where those profits or gains are attributable to a relevant planning decision by a planning authority, are being abolished from 1 January 2015.

SECTION 44-CAPITAL GAINS TAX (CGT) RETIREMENT RELIEF

CGT retirement relief is available to farmers on, among other things, the disposal of land that has been leased in certain circumstances. On foot of the AgriTax Review, s.598 TCA is being amended so that, subject to other conditions, land that has been leased for up to 25 years in total (increased from 15) ending with disposal will qualify for the relief.

Amendments are also being made to provide (in the case of land disposals outside the family) that land currently let under conacre arrangements which end with disposal by 31 December 2016 or which (before 31 December 2016) is instead leased out for minimum periods of 5 years to a maximum of 25 years ending with disposal will, subject to other conditions, also qualify for CGT retirement relief.

SECTION 43-CAPITAL GAINS TAX (CGT) FARM RESTRUCTURING RELIEF

Section 604B Taxes Consolidation Act 1997 (TCA) provides for a capital gains tax relief for farm restructuring where the first transaction in the restructuring (e.g. sale, purchase or exchange of land) is carried out by 31 December 2015 with the restructuring to be completed within 24 months. As a result of the AgriTax Review, the deadline for the completion of the first restructuring transaction is being extended to 31 December 2016. Teagasc certification guidelines are being amended to enable whole farm replacement to be eligible for the relief subject to meeting the conditions laid down by Teagasc. The amendment of the guidelines does not require amendment of the TCA.

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CAPITAL ACQUISITIONS TAX

SECTION 74-CAPITAL ACQUISITIONS TAX (CAT) AGRICULTURAL RELIEF

CAT relief is available in respect of gifts and inheritances of agricultural property including land, subject to certain conditions. On foot of the AgriTax Review, changes are being introduced to target the relief so that agricultural property is actively used for agricultural purposes. From 1 January 2015, and subject to other conditions, the relief will be available only in respect of agricultural property gifted to or inherited by active farmers and to individuals who are not active farmers but who lease out the property on a long-term basis for agricultural use to such farmers.

DIRT

SECTION 20-DIRT FOR FIRST TIME HOUSE BUYERS

A relief from DIRT on savings used by first time house buyers is being introduced in the context of tightening loan–to-value mortgage requirements. This will enable a first time buyer purchasing a home to apply for a refund of the DIRT they paid on the interest earned on savings used towards the deposit on a home.

AGRI TAXATION

SECTION 18- AMENDMENTS TO LAND LEASING AND INCOME AVERAGING TAX PROVISIONS:  Increase the amounts of income exempted from long term leasing by 50%

 Introduce a fourth threshold for lease periods of 15 or more  Allow relief where the lessee is a non-connected company  Remove the 40 years of age threshold for leasing relief

 Allow income averaging where there is on-farm diversification  Increase income averaging from 3 to 5 years

SECTION 66-AGRICULTURAL LEASES

Agricultural leases of between 5 and 35 years in duration to active farmers will be exempt from Stamp Duty.

SECTION 69-CONSANGUINITY RELIEF

Consanguinity relief, which applies to transfers of non-residential property to certain relatives, is due to expire on 31 December 2014. This relief, which halves the applicable rate of Stamp Duty, is being extended for a period of three years in certain circumstances where the transferee is an active farmer.

CORPORATION TAX

SECTION 38-COMPANY RESIDENCE

This Section amends Ireland’s company tax residence rules to provide that all companies that are incorporated in Ireland will be automatically tax resident here (unless otherwise determined under a

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bilateral tax treaty which supersedes domestic law). The change will come into effect for new companies from 1 January 2015 while a transition period will apply until 2020 for existing companies. This change will bring Ireland’s rules into line with the rest of the OECD.

SECTION 35-INTANGIBLE ASSETS

Ireland’s current regime for intangible assets provides capital allowances for expenditure incurred on the provision of certain intangible assets for use in an Irish trade. This measure is being enhanced:

- The use of such allowances is currently restricted to a maximum of 80% of the income from the relevant trade in which the acquired assets are used. Any related interest expense deduction in respect of relevant borrowings incurred on such an acquisition is similarly restricted. This restriction on aggregate allowances (and interest) will be removed in the upcoming Finance Bill.

- The Bill will also amend the definition of ‘specified intangible asset’ contained in this provision to explicitly include customer lists.

These measures will apply in respect of accounting periods commencing on or after 1 January 2015.

SECTION 23-RESEARCH AND DEVELOPMENT (R&D)TAX CREDIT

The R&D tax credit applies to the amount of qualifying R&D expenditure by a company in a given year that is in excess of the amount spent in 2003, which is the base year for the regime. As recommended in the 2013 Review of Ireland’s R&D Tax Credit, the base year restriction is being removed. This will apply to accounting periods commencing on or after 1 January 2015. In addition, a technical amendment will ensure that a provision made in the Finance Act 2010 operates as intended.

SECTION 34-3YEAR CORPORATION TAX RELIEF FOR START UP COMPANIES

This measure provides relief from corporation tax on trading income (and certain capital gains) of new start-up companies in the first 3 years of trading. This relief was due to expire at the end of 2014 and is being extended to the end of 2015. A review of the operation of this measure will take place in 2015.

SECTION 33 -ACCELERATED CAPITAL ALLOWANCES FOR COMPANIES INVESTMENT IN ENERGY

EFFICIENT EQUIPMENT

This is a measure to encourage companies to invest in energy efficient equipment. It allows them to deduct 100% of expenditure incurred on eligible equipment (that meets specified energy efficient criteria) in computing taxable trading profits in the year of purchase rather than over the usual eight year period for plant and machinery. This measure was due to expire at the end of 2014 and is being extended to the end of 2017, following a review of the measure that was undertaken in 2014 by the Department of Communications, Energy and Natural Resources.

INDIRECT TAXES

VALUE-ADDED TAX

SECTION 60-FARMERS’FLAT-RATE ADDITION

The farmers’ flat-rate addition is being increased from 5% to 5.2% with effect from 1 January 2015. The flat-rate scheme compensates unregistered farmers for VAT incurred on their farming inputs. The flat-rate addition is reviewed annually in accordance with the EU VAT Directive and the increase to 5.2% in 2015 achieves full compensation for farmers.

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EXCISE

SECTION 53-TOBACCO PRODUCTS TAX

The excise duty on a packet of 20 cigarettes in the most popular price category was increased by 40 cent (including VAT), with a pro-rata increase on other tobacco products, while the excise duty on a 25g of roll-your-own tobacco was increased by a further 20 cent (including VAT). This measure was provided for by a Financial Resolution of 14 October 2014.

SECTION 55-VEHICLE REGISTRATION TAX (VRT)

The VRT relief available for the purchase of hybrid electric vehicles, plug-in hybrid electric vehicles, plug-in electric vehicles, and electric motorcycles is being extended to 31 December 2016.

SECTION 52-ALCOHOL PRODUCTS TAX

The special relief reducing the standard rate of Alcohol Products Tax by 50% on beers produced in microbreweries which produce not more than 20,000 hectolitres per annum is being extended to apply to microbreweries which produce not more than 30,000 hectolitres per annum.

SECTION 48-DEFERRAL OF EXCISE PAYMENT ON MINERAL OIL

Excise duty on mineral oil will now be collected on the 15th day of the month following delivery. This brings mineral oil in line with other excisable products that benefit from a deferral. To allow for Revenue to revise the collection system, this measure will be subject to a commencement order.

SECTION 49-NATURAL GAS AS A TRANSPORT FUEL

Mineral Oil Tax and Carbon Tax legislation is being amended to provide for Natural Gas and BioGas as a transport fuel with the excise rate at the current EU Minimum rate.

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INCOME TAX

SECTION 9-TRUSTS FOR PERMANENTLY INCAPACITATED INDIVIDUALS

This amendment provides that undistributed funds held in a Trust can be transferred to the incapacitated individual’s estate on his or her death, where there is a spouse and/or children.

SECTION 6-MORTGAGE INTEREST RELIEF

This amendment extends the relief to individuals who derive the major part of their income in Ireland, in respect of qualifying loans on principal private residences situated in European Economic Area countries, in order to comply with the freedom of movement provisions of the EU Treaties.

SECTION 12-DUAL ABODE ALLOWANCE

This amendment restricts the ability of Ministers and Ministers of State from constituencies outside Dublin, to deduct expenses associated with the retention of a second property, in order to allow them to conduct their duties, such that water charges and local property tax will not be allowed as qualifying expenses.

OTHER INCOME TAX

SECTION 16-TAX RELIEF ON DONATIONS TO APPROVED BODIES

This scheme is being amended to ensure only "eligible charities" qualify for tax relief for the purposes of the donations scheme. The current restriction in Schedule 26A of the Taxes Consolidation Act 1997 that requires the withdrawal of an authorisation for the purposes of the donations scheme to be prospective is being removed to allow for retrospective withdrawal. Retrospective withdrawal of an authorisation will impact solely on the "charity" and not on donors.

SECTION 4 - TAX TREATMENT OF DIRECTORS OF COMPANIES AND EMPLOYEES GRANTED

RIGHTS TO ACQUIRE SHARES OR OTHER ASSETS

The current reporting requirement in Section 128(11) of the Taxes Consolidation Act 1997 is being amended to provide that the details regarding the granting of rights to employees to acquire shares or other assets are reported by their employers in such electronic manner as the Revenue Commissioners may specify. This will allow for the reporting of such transactions in electronic format whereas it is currently required in writing.

SECTION 29-INCENTIVES FOR CERTAIN AVIATION SERVICES FACILITIES

The legislation providing for a scheme of accelerated capital allowances for the construction of buildings for use in the maintenance, repair, overhaul or dismantling of aircraft is being amended to meet the concerns of the European Commission in order to qualify for State Aid approval.

INCOME TAX/CAPITAL GAINS TAX

SECTION 22 - SECURITIES ISSUED BY THE COMPANY TO BE ESTABLISHED UNDER SECTION 5 OF THE GAS REGULATION ACT 2013

Section 37 of the Taxes Consolidation Act 1997 (TCA) provides that interest on securities issued by certain semi-State companies may be paid by them without deduction of tax. Section 607(1)(d)

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TCA provides that securities issued by certain commercial semi-State bodies shall not be chargeable assets for Capital Gains Tax. The company to be established under section 5 of the Gas Regulation Act 2013 is being added to the list of companies who qualify for these exemptions.

CAPITAL GAINS TAX

SECTION 40-TEMPORARY NON-RESIDENTS

Section 29A TCA is designed to counter avoidance of CGT by individuals who become temporarily non-resident for tax purposes by deeming that certain assets disposed of by an individual in any year of non-residence are disposed of and reacquired at their market value on the last day of the year the individual left the State to reside elsewhere, thus imposing a CGT charge. The EU Commission has raised doubts about the compliance of the Section with aspects of EU law, specifically that no account is taken of a possible reduction in the market value of the assets at the moment of their disposal by an individual as compared with the market value on the last day the individual was resident in the State. Section 29A is being amended to deal with these concerns.

SECTION 41-WORKS OF ART AS “WASTING ASSETS”

Section 560 TCA is being amended to ensure that works of art (which generally increase in value with age) do not qualify for exemption from CGT on disposal as “wasting assets” which could occur in certain circumstances where such works are regarded as items of plant.

SECTION 39-TIME LIMITS FOR MAKING AN ASSESSMENT TO CLAW BACK CERTAIN CGT RELIEFS

The time limits specified in sections 598, 599 and 611 TCA, which relate to CGT retirement relief and CGT relief on disposals of assets to the State or a charity, are no longer relevant as CGT is a self-assessment tax. The proposed deletion of the time limits in these Sections will mean that the general 4 year time limit for making or amending assessments will instead apply subject to the taxpayer having made a full and true return.

SECTION 46-CGT ENTREPRENEUR RELIEF

CGT entrepreneur relief was introduced by Budget 2014 and Finance (No 2) Act 2013 subject to obtaining EU State-aid approval. Such approval is not required where the relief complies with the EU General Block Exemption Regulation (GBER) which came into force on 1 July 2014. The Bill includes amendments to s.597A TCA (particularly as regards the enterprises at which the relief is aimed and the scale of the initial investment in those enterprises) to provide for compliance with the GBER. Other amendments to s.597A are included in the Bill to improve the effectiveness of the relief. Section 597A will be commenced with effect from 1 January 2014.

SECTION 45-SINGLE FARM PAYMENT ENTITLEMENTS

A commitment was given by the Minister earlier this year to provide for an exemption from CGT on any chargeable gains arising from the disposal by farmers of payment entitlements under the Single Payment Scheme where all of those entitlements were fully leased out and where the owners, because of the change in CAP regulations, were advised by the Department of Agriculture, Food and the Marine, to transfer their entitlements to an “active” farmer by 15 May 2014. This Section gives effect to that commitment.

SECTION 42-VODAFONE PLC –TREATMENT OF RETURNS OF VALUE

This section provides for the treatment of “returns of value” payments of €1,000 or less made by Vodafone plc to its Irish shareholders as capital receipts for tax purposes unless shareholders specifically opt to have the returns treated as income. Since many small Irish investors are shareholders in Vodafone plc on foot of an original investment in Eircom, and are carrying capital

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losses for tax purposes as a result of that original investment, the effect of the provision will be that no tax would be due on the returns of value affected.

CAPITAL ACQUISITIONS TAX

SECTION 75-CAT BUSINESS RELIEF

CAT relief applies to the gift and inheritance of business assets and is intended to encourage the inter-generational transfer of businesses. This Section amends Section 93 of the Capital Acquisitions Tax Consolidation Act 2003 (CATCA) to allow for the aggregation of the shareholdings of spouses or civil partners when determining control of a business for the purpose of applying CAT relief to the gift or inheritance of personally held business assets. This will remove a difficulty in the proper provision of the relief in the case of such assets.

SECTION 72-DISCRETIONARY TRUSTS SET UP FOR CHARITABLE PURPOSES

Section 17 CATCA provides exemption from discretionary trust tax for discretionary trusts set up exclusively for public and charitable purposes in the State or in Northern Ireland. The territorial limit in that Section is being removed so that the relief will apply to such trusts wherever situated, provided the Revenue Commissioners are satisfied that the gift or inheritance is applied to purposes which (in accordance with the laws of the State) are public or charitable.

SECTION 73-CERTAIN PAYMENTS MADE OR PROVIDED FOR BY PARENTS

Section 82(2) CATCA provides, among other things, for CAT exemption for normal and reasonable payments made by living parents for the support, maintenance or education of their children without age restriction. There is evidence that this exemption is being abused in respect of payments being made by parents to their healthy mature adult children. Section 82(4) CATCA exempts payments made from a discretionary trust (where both parents are dead) to the orphaned minor children of such parents (e.g. only where the children are aged under 18 years). Amendments are being made to section 82 CATCA to equalise the CAT treatment of payments made to orphaned children and to children of living parents by providing for the exemptions in both scenarios to apply up to age 25 where the children are in full time education.

STAMP DUTY

SECTION 70-YOUNG TRAINED FARMER RELIEF

An additional course is being added to the list of relevant qualifications required to apply for Young Trained Farmer relief from Stamp Duty. This course is also being added to the list of qualifying courses for “stock relief” from Income Tax for young trained farmers.

SECTION 65&67-NATIONAL TREASURY MANAGEMENT AGENCY

The definition of accountable person under the Stamp Duty legislation is being amended to exclude the National Treasury Management Agency or the Minister for Finance (in relation to a function which is capable of being delegated to the National Treasury Management Agency under section 5 of the National Treasury Management Agency Act, 1990). This amendment is necessary as section 108 of the Stamp Duties Consolidation Act 1999 is being abolished.

The Stamp Duty legislation is also being amended to ensure that certain types of securities, including debt securities, issued by the Minister for Finance or by the National Treasury Management Agency on his behalf and other securities issued by the National Treasury Management Agency on behalf of the Minster for Agriculture are exempt from stamp duties.

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SECTION 68-BANK LEVY

The Stamp Duty legislation is being amended to ensure that Revenue may raise an assessment in respect of any financial institution that does not pay the bank levy.

SECTION 77-DOMICILE LEVY PENALTIES

The Domicile Levy is being included in the definition of "tax" in the Act so that Revenue can impose penalties for failure to deliver a return in respect of the Levy or for deliberately or carelessly making an incorrect return in respect of the Levy. An amendment is also being made so that Revenue can issue a notice to a person to deliver a return where they have reason to believe that a person is liable to the Levy.

SECTION 19-SOCIAL INSURANCE FUND –TAX ON INTEREST

An exemption from Deposit Interest Retention Tax (DIRT) is provided for in respect of income relating to the Social Insurance Fund. The amendment is specific to the Minister for Social Protection in respect of income derived from accounts held under section 9 of the Social Welfare Consolidation Act 2005. The proposed legislation will avoid circular flow of Exchequer subvention used to pay DIRT, and facilitate application of gross accounting in accordance with Public Financial Procedures.

PENSION TAXATION

SECTION 17 -APPROVED RETIREMENT FUNDS (ARFS) AND “VESTED” PERSONAL RETIREMENT

SAVINGS ACCOUNTS (PRSAS).

This amendment will close off a number of tax avoidance schemes which are linked to the use of ARFs and “vested” PRSAs. PRSAs are referred to as “vested” when benefits have commenced to be drawn down from them.

SECTION 17-PENSION CONTRIBUTIONS BY CERTAIN FIXED-TERM CONTRACT EMPLOYEES

This sections will allow certain fixed-term contract employees and former employees of the National University of Ireland Galway (NUIG) to obtain tax relief for pension contributions made or to be made to the NUIG pension scheme in respect of the tax years 2003 to 2008 arising from the delayed implementation of certain pension related requirements of the Protection of Employees (Fixed Term Work) Act 2003.

SECTION 17-STANDARD FUND THRESHOLD (SFT) AND PENSION ADJUSTMENT ORDERS (PAOS) The legislation giving effect to the maximum allowable pension fund at retirement for tax purposes (the Standard Fund Threshold or SFT) currently provides that a PAO, which designates some of a pension scheme member’s pension benefits to his/her former spouse or partner, is ignored in determining whether at the point of draw-down of those benefits the SFT (or a higher Personal Fund Threshold) has been exceeded and a chargeable excess arises. A chargeable excess is subject to an immediate tax charge of 41%. Currently, this chargeable excess tax is paid upfront by the pension administrator and is recovered solely from the pension scheme member’s remaining pension benefits notwithstanding that a significant part of the overall pension benefits may be designated to his or her spouse or partner. This Section provides for the apportionment of any chargeable excess tax in accordance with the terms of the PAO so that both the member and non-member spouse share the tax charge equitably.

SECTION 17 - IMPUTED DISTRIBUTION ARRANGEMENTS FOR ARFS AND ACCESS TO APPROVED

MINIMUM RETIREMENT FUNDS (AMRFS)

This Section provides for a reduction from 5% to 4% in the rate of the annual imputed or notional distribution of the assets of ARFs and “vested” PRSAs in cases where the owner of the ARF or

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“vested” PRSA is aged between 60 and 70 years and the aggregate value of assets in ARFs or “vested” PRSAs in the ownership of such individuals is less than €2 million. The purpose of the change is to reduce the risk that the owners of ARFs in these circumstances will outlive their retirement funds. The imputed distribution remains at 5% where the ARF owner is aged 70 years or over and at 6% where the aggregate value of assets in ARFs or “vested” PRSAs owned by an individual is greater than €2million. The Section also allows for a maximum annual withdrawal, subject to taxation at the marginal tax rate, of 4% of the value of assets in an AMRF in place of the existing access to the accrued income and gains from the investment of those assets.

LIVING CITY INITIATIVE

SECTION 28-LIVING CITY INITIATIVE

This section provides for an expenditure cap on the amount that can be claimed under the commercial element of the initiative. The cap will be €1.6m of expenditure for companies and €400k for individuals who invest in eligible commercial properties under the initiative. This change means that the initiative comes under EU de minimis State Aid rules. There will be no expenditure cap on the residential element of the initiative. There is also a requirement that taxpayers must provide certain information to the Revenue Commissioners such as the amount of expenditure involved, before they will be able to claim the tax relief.

FILM RELIEF

SECTION 21&82-FILM RELIEF

These sections make a number of provisions relating to the practical operation of the new S481 which is due to commence in January 2015. These details have been worked out in a technical group set up by Revenue to tease out any operational issues with film industry representatives.

CORPORATION TAX

SECTION 25-REAL ESTATE INVESTMENT TRUST (REIT)COMPANIES

This section amends Part 20 of the TCA to ensure that capital gains tax group relief provisions cannot give rise to an unintended tax exemption on gains accrued prior to conversion to REIT status. This is a preventative measure – no such transactions have occurred to date. The Bill also makes a number of technical amendments to REIT legislation in Part 25A TCA, including a provision to exempt the deposits of REITs from deposit interest retention tax (DIRT). This exemption does not change the underlying tax treatment of interest earned by REITs.

SECTION 26-TAX TREATMENT OF RELEVANT ALTERNATIVE INVESTMENT FUNDS (AIFS)

Following the transposition of the Alternative Investment Fund Managers Directive (AIFMD), the Bill amends section 747G of the TCA to provide that non-Irish-resident AIFs will not be brought into the scope of Irish tax solely as a consequence of being managed by an Irish AIFM or by an Irish branch or agency of an AIFM authorised in an EEA State.

SECTION 31-SHORT-LIFE ASSET OPERATING LESSORS

This section amends section 80A of the TCA to remove a threshold which restricts the application of the section for operating lessors by reference to their short-life asset portfolio value in 2010. Section 80A aligns the deduction for the cost of acquiring such assets with their expected life span. This does not change the ultimate value or time period of the deduction, only the manner in which

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the deduction is spread over the asset’s lifespan. Removal of the threshold brings parity between lessors established pre- and post-2010.

SECTIONS 32,36,37&35-OTHER CORPORATION TAX CHANGES

A number of amendments of a more technical nature are summarised hereunder:

 Section 32 provides for The Credit Union Restructuring Board and the Health and Social Care Professionals Council to be included in the list of specified non-commercial State-sponsored bodies that are exempt from certain tax provisions (Schedule 4 of the TCA).

 Section 36 provides for a technical change to Section 623 of the TCA, to remove the current legislative uncertainty around the due date for a specific charge to Chargeable Gains Tax (CGT) for companies. This relates to the deferred CGT charge for the intra-group transfer of an asset, which may be clawed back if a company leaves the group having availed of relief on an intra-group acquisition within the previous 10 years. This change will clarify that the tax arising under this section will be tax due and payable for the accounting period in which the company leaves the group.

 Section 37 contains a technical amendment to Schedule 17A of the TCA. This Schedule deals with transitional arrangements where a company chooses or is obliged to prepare its accounts under International Accounting Standards or equivalent Irish Generally Accepted Accounting Principles and calculate tax on that basis. This amendment will, from I January 2015, extend these transitional arrangements to companies who are transitioning to the new Irish & UK Financial Reporting Standards to the extent that these standards embody International Accounting Standards.

 Section 35 provides for the non-application of a balancing charge under section 288 TCA on the transfer of an intangible asset to a connected company after more than 5 years in use in a trade. The amendment provides that where a company claims capital allowances on expenditure incurred on the provision of an intangible asset and, after a 5 year period, transfers the asset to a connected company, the acquiring company will be able to claim capital allowances on the tax written down value of the asset (i.e. the amount of unclaimed allowances) at the time of the transfer and the transferring company will not be subject to a balance charge.

TAX ADMINISTRATION AND REVENUE POWERS

SECTION 79(AND SCHEDULE 1)-GENERAL ANTI-AVOIDANCE LEGISLATION

This section amends the general anti-avoidance legislation in the Taxes Consolidation Act 1997 by replacing the existing sections 811 and 811A with new sections 811C and 811D. As a transitional measure, it also provides that a person who entered into a tax avoidance transaction on or before 23 October 2014, and who, before 30 June 2015, makes a full disclosure and full payment of all tax due to the Revenue Commissioners, will not be subject to the surcharge provided for in section 811A. Also, any interest payable in cases covered by the transitional measures will be capped at 80 per cent of the interest otherwise payable.

The new Section 811C provides that where a person enters into a transaction and it would be reasonable to consider, based on a number of specific factors, that the transaction was a tax avoidance transaction, that person shall not be entitled to benefit from any tax advantage arising from that transaction.

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Section 811D provides that where a person enters into a tax avoidance transaction and claims the benefit of a tax advantage, contrary to section 811C, an additional payment in the form of a surcharge will be due and payable. In order to provide protection to taxpayers, a taxpayer who enters into a transaction, and who has a concern that section 811C could apply, may file a ‘protective notification’.

Section 811D also provides that where a taxpayer entered into a transaction and claimed the benefit of a tax advantage, contrary to either section 811C or one of the specific anti-avoidance provisions listed, that person may avail of a reduced surcharge amount if a disclosure is made to Revenue. The protections offered by ‘protective notifications’ do not apply where the transaction was one which was disclosable to Revenue under the Mandatory Disclosure regime, unless the taxpayer was unaware that the transaction was a ‘disclosable transaction’.

SECTION 80(AND SCHEDULE 2)-MANDATORY DISCLOSURE

This section incorporates most of the rules relating to the Mandatory Disclosure regime into the Taxes Consolidation Act 1997. In addition, the section introduces a requirement that the Revenue Commissioners assign a unique Transaction Number to each scheme notified. In addition, any transaction that seeks to avoid tax through the use of a discretionary trust is now a disclosable transaction for the purposes of the Mandatory Disclosure regime.

This section also inserts a new chapter into Part 33 providing for payment notices. Where the Appeal Commissioners make a determination relating to a tax avoidance transaction under section 811C, in relation to one of the specific anti-avoidance provisions or in relation to a transaction that was a disclosable transaction under the Mandatory Disclosure regime, then the Revenue Commissioners may issue a payment notice to that taxpayer requiring payment of tax due on foot of the determination of the Appeal Commissioners.

In addition, where the Appeal Commissioners have made a determination in one case and it is determined by the Revenue Commissioners that other taxpayers had engaged in the same transaction or similar transactions, a payment notice may be issued by the Revenue Commissioners to the other taxpayers. These taxpayers may appeal the determination.

SECTION 87-ELECTRONIC TAX CLEARANCE

The Department of Finance requires applicants for certain licences and recipients of payments in respect of Public Service Contracts, Grants, Subsidies and similar type payments to be tax compliant. Currently, application for tax clearance is made in paper format and a tax clearance certificate is given by Revenue if the applicant's tax affairs are up to date at the time of application. Such certificates, once issued, are in general valid for 12 months. This process is inefficient and less than fully effective. Therefore this section provides for the introduction of an electronic tax clearance system to improve the efficiency and effectiveness of the existing tax clearance process. The tax compliance status of applicants will be reviewed on an on-going basis and tax clearance certificates may be issued, refused or (where a certificate was issued) rescinded, depending on the tax compliance status of applicants when reviewed. The new tax clearance procedures will come into operation from a date to be specified by regulation.

SECTION 85-SECURITY REQUIRED BY COLLECTOR-GENERAL

This section amends section 960S of the Taxes Consolidation Act, 1997 to address certain difficulties associated with the application of the current provision, particularly in relation to directors / shareholders of a company who establish a new company and set up in business again.

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SECTION 30-TAX EXEMPTION OF CERTAIN INCOME

This is an anti-avoidance item. Recently it has come to the notice of Revenue that schemes are being sold which involve a person resident in a tax haven country selling the right to receive a dividend to Irish individuals. The section inserts a new subsection (5) into section 812, Taxes Consolidation Act 1997, which provides, firstly, that the section does not apply if the receipt of the interest by the owner of the securities would not have been chargeable to tax in the State and, secondly, that the section does not apply if the proceeds from the sale or transfer of securities are taxable under the rules applicable to Case I of Schedule D.

SECTION 10-MANUFACTURED LOSSES

This is an anti-avoidance item. It has come to the notice of Revenue that schemes are being used to generate trading losses so as to reduce the taxable income of an individual. This section modifies section 381 of the Taxes Consolidation Act 1997 to limit relief in the case of part time trades which are not carried on a commercial basis.

SECTION 84 - DEFINITION OF “FINANCIAL INSTITUTION” FOR THIRD PARTY REPORTING OF

PAYMENTS

This section amends section 891B of the Taxes Consolidation Act 1997 which requires financial institutions such as banks and assurance companies to make automatic annual returns to the Revenue Commissioners relating to customers to whom they have made payments of interest and other profit type payments. The definition of financial institution is being expanded to include agents of the NTMA in respect of State savings products. The primary aim of collecting this information is to improve Revenue's capacity to detect non-compliance. While the products themselves will not result in additional tax yield due to their tax exempt status, it will support the identification of funds that may arise from untaxed sources or activities.

SECTION 81-FINANCIAL INFORMATION REQUIRED FOR CTRETURN

Section 884 of the Taxes Consolidation Act 1997 is amended to provide that the accounts information to be submitted electronically with the corporation tax return is that required by the notice to deliver the return or as specified on the prescribed form of the return. The section also amends eFiling and self-assessment legislation, as a consequence.

SECTION 7-PROFESSIONAL SERVICES WITHHOLDING TAX (PSWT)

PSWT is the scheme whereby tax is deducted at source by various "Accountable Persons" from payments made by them to individuals and companies in respect of "professional services". Accountable Persons include Government Departments, local authorities, the Health Service Executive, commercial and non-commercial semi-State bodies and their subsidiaries. This section amends Schedule 13 of the Taxes Consolidation Act 1997 (the list of Accountable Persons) by removing four entities that are no longer Accountable Persons and adding three new ones

SECTION 86-NON-APPLICATION OF SURCHARGE

This section amends section 1084 of the Taxes Consolidation Act 1997 dealing with surcharge for late returns. It provides that a taxpayer will not be subject to a surcharge where the taxpayer submits a timely but incorrect return and a penalty is imposed under section 1077E for deliberately or carelessly making an incorrect return. A minor wording change to section 1084 is included also, to update the terminology therein.

SECTION 15-RELEVANT CONTRACTS TAX PENALTIES

This section amends sections 530 and 530F of the Taxes Consolidation Act 1997 so that the penalty for the non-operation of RCT is set at a level to ensure the Exchequer is protected but also that the penalty is proportionate and reasonable. In moving to a different penalty regime, arguments as to whether the same income is doubly taxed are avoided. It also ensures that there can be no argument

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as to the entitlement of a sub-contractor to a credit for any tax withheld. The section also requires a principal contractor to submit an unreported payment notification to the Revenue Commissioners in instances where Relevant Contract Tax was not operated on relevant payments.

SECTION 78-DEFINITION OF “CHARGEABLE PERSON”

This section amends the definition of a 'chargeable person' in section 959B of the Taxes Consolidation Act, 1997 to reflect the position outlined by Revenue in their February 2014 e-Brief 15/14. This confirmed that where a person pays his or her tax through the PAYE system and has a small amount of other income which is either coded against tax credits or fully taxed at source, that person is not a chargeable person. This ensures that an individual who pays tax through PAYE but also has a small amount of deposit interest in a year, which is taxed at source through DIRT, will not have to file a tax return.

SECTION 83-RECORD KEEPING BY PERSONAL REPRESENTATIVES

The six-year retention period for record keeping is being extended where claims, audits, enquiries, investigations or judicial processes are active after this period. This section provides that in such circumstances, related records, including linking documents, must be retained until such time as the claim, audit, enquiry, investigation or judicial process has been finally determined. Also, while there is a general obligation under section 886 of the Taxes Consolidation Act 1997 for taxpayers to keep records for tax purposes for a period of six years, there is currently no direct requirement for a personal representative, either an executor or administrator, to keep records for a similar period. This section therefore provides for the retention of records by a personal representative of a deceased person.

INTERNATIONAL TAX AGREEMENTS

SECTION 88 - RATIFICATION OF DOUBLE TAX AGREEMENTS (DTAS) WITH THAILAND AND

BOTSWANA, AND PROTOCOLS TO THE DTAS WITH BELGIUM,LUXEMBOURG, AND DENMARK. This section provides for the listing of the Orders containing the above Agreements in Schedule 24A of the Taxes Consolidation Act 1997. This is a routine item that is generally included in Finance Bills. It is the final stage of the ratification process for these agreements.

INDIRECT TAXES

VALUE-ADDED TAX

SECTION 59-RETENTION OF RECORDS

The six-year retention period for record keeping is being extended where claims, audits, enquiries, investigations or judicial processes are active after this period. Currently, where an issue gives rise to an audit, etc. which extends beyond the six-year retention period, there is no explicit legal obligation on the claimant to retain the related records. This amendment provides that in such circumstances, related records, including linking documents, must be retained until such time as the claim, audit, enquiry, investigation or judicial process has been finally determined.

SECTION 61-ANTI-AVOIDANCE MEASURE:ISSUE OF VATDOCUMENTS

This anti-avoidance measure will allow Revenue to require a business to issue a receipt to all customers presenting themselves as not registered for VAT, containing all of the particulars of an invoice. The measure would apply to persons who generally supply to trade customers and is aimed at deterring the practice of suppliers not issuing VAT invoices where they are aware that their customer is registered for VAT. It would also help identify the non-compliant customers.

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SECTION 62-JOINT AND SEVERAL LIABILITY

In accordance with Article 205 of the EU VAT Directive, provision is being introduced to make persons joint and severally liable for VAT in relation to the supply of goods or services, excluding imports from outside the EU, where those persons knew or were reckless in participating in VAT evasion. This is an anti-avoidance measure which is expected to deter persons from engaging in transactions that they might consider to be fraudulent.

SECTION 63-FOSTERING

The existing VAT exemption for non-profit making bodies supplying child fostering services is being extended to regulated commercial bodies supplying similar fostering services. The HSE contract profit and non-profit bodies to undertake fostering services and currently there is a distortion between the VAT treatment of both bodies providing the same service. This change will eliminate the distortion.

SECTION 63 - DEFINED CONTRIBUTION PENSION FUNDS - ATP PENSIONSERVICES ECJ JUDGEMENT

The current VAT exemption for the management of special investment funds will be extended from 1 March 2015 to include certain defined contribution pension funds, in accordance with the judgment in the ATP Pension Service European Court of Justice case C-464/12. The management of defined contribution pension funds will qualify for VAT exemption where they are funded by the customer who will avail of the pension, and where the customer bears the investment risk. Furthermore, the investments must be pooled and invested using a risk spreading principle, and as such the management of single member schemes will not qualify for exemption.

SECTION 63-MEMBER-OWNED GOLF CLUB FEES –BRIDPORT ECJCASE JUDGEMENT

Member-owned golf clubs are currently liable to charge VAT at 9% on green fees charged to non-members, and in a small number of cases on membership fees. From 1 March 2015, however, all green fees and membership fees charged by member-owned golf clubs will be exempt from VAT, in compliance with the judgment in the Bridport & West Dorset Golf Club Ltd ECJ case (C-495/12). Commercial golf clubs, however, were not considered in the ECJ case and remain subject to VAT at the 9% rate on their green fees.

SECTION 63-HERBAL TEA

The definition of unprepared tea, for the purposes of the application of the zero rate of VAT, is being revised to reflect other variations of teas available on the market, such as herbal teas and fruit infusions. As herbal and fruit teas are marketed in the same manner as black tea, and treated as such by consumers, it was decided to include them in the definition of unprepared tea.

EXCISE

SECTION 51-MINOR TECHNICAL AMENDMENTS

There are a number of minor technical amendments included which will update and correct references.

SECTION 56&57-VEHICLE REGISTRATION TAX

Provision is being made for the payment of interest in respect of VRT repaid under the Export Repayment Scheme.

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SECTION 47-POWER OF OFFICERS (BETTING DUTY)

Provision is being made to extend the power of entry of authorised officers to any premises within which, they reasonably believe, a betting exchange is operating. This provision is subject to the commencement of the Betting (Amendment) Bill 2013.

SECTION 50-MINERAL OIL TRADERS LICENCE

Provision is being made to extend the information Revenue may request in the mineral oil traders licence application. Provision has also been made to refuse or revoke applications where false information is provided and to refuse applications where an applicant was refused previously and this was upheld on appeal.

SECTION 54-DISABLED DRIVERS AND DISABLED PASSENGERS (TAX CONCESSIONS)SCHEME

Provision is being made to remove the requirement that the cost of adaptation of a qualifying vehicle must consist of not less than 10% of the value of the vehicle.

MINOR TECHNICAL AMENDMENTS

SECTION 89-MINOR TECHNICAL AMENDMENTS

There are a number of minor technical amendments included which will update and correct references.

NON TAX ITEM

SECTION 91-CAPITAL SERVICES REDEMPTION ACCOUNT (CSRA)

This section repeals the requirement to make payments from the Exchequer to the CSRA, to cover capital and interest payments on borrowings to fund voted capital expenditure, where the required number of annuity payments have not already been met for annuities provided for in previous Finance Acts. Once the State exits the excessive deficit procedure, future policy on the National Debt will be guided by the debt rule, section 4 of Fiscal Responsibility Act 2012.

The Section also reduces the administrative burden on the reporting of the CSRA. The CSRA will now appear as a note to the National debt account.

SECTION 90-SMALL SAVINGS RESERVE FUND

The Small Savings Reserve Fund (SSRF) was introduced at a time when the Exchequer balance was used to measure the fiscal position. The SSRF was used to spread the expense from government savings products over a number of financial periods. In line with international standard, fiscal performance is now measured in general government terms. As this is measured on an accrual basis, the SSRF is now longer required.

References

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