Key Changes In Ireland's Finance Bill 2025

The Irish Finance Bill 2025 (the "Bill") was published on 16 October. For large international groups operating in Ireland, the key changes to be aware of are:

• Amendments to the regime that applies to transfers of IP where capital allowances have been claimed in respect of that IP;
• Improvements to the R&D tax credit;
• Improvements to Ireland's participation exemption for foreign dividends;
• A new provision that specifies how certain foreign bodies corporate should be classified for Irish tax purposes;
• A new exemption from dividend withholding tax for investment limited partnerships; and
• Amendments to Ireland's Pillar Two rules.

We have included some additional detail on each of these changes below.