This summary outlines the key tax policy measures announced in
the Finance Bill 2025 (the
“Bill”).
Participation exemption
Some of the most called-for changes implemented by the Bill
limit the anti-avoidance provisions in and extend the scope of the
dividend participation exemption (the
“DPE)” introduced by Finance Act 2024
from 1 January 2025.
Geographic scope
The original form of the DPE was limited to companies resident
in an Irish treaty country or EEA state in scope. In a welcome
move, the Bill will extend this to territories that generally
impose a foreign withholding tax on distributions, provided that
foreign withholding tax has been paid by the relevant subsidiary on
the full amount of the distribution and is non-refundable.
