I move amendment No. 33: In page 23, line 9, to delete “(12) Failure” and substitute “(13) Failure”.

I move amendment No. 34: In page 23, line 9, to delete “subsection (10)” and substitute “subsection (11)”.

On 14 September, as the Deputy will be aware, the ECB increased the main lending rate by 0.25%. It was the tenth increase in official rates since the summer of 2022, bringing the ECB's main lending rate to 4.5%. I have consistently said over the past months that the appropriate time to make a decision on whether it was appropriate to provide support to mortgage holders because of the additional burden imposed by interest rate increases would be at budget time, and that is exactly what I did. We are acutely consciou…

As the Deputy well knows, there are a whole range of measures in budget 2024 designed to help people with the cost of living. We are focusing here on one particular measure. There are changes to our income tax system, changes to our social welfare system, energy credits, exceptional lump sum payments and measures to reduce the cost of accessing public services. The budget must be considered in the round and there are a wide array of measures the households in question will benefit from in the context of budget 2024…

The purpose of the residential premises rental income relief is to provide for a new tax incentive for small-scale landlords. This measure is specifically targeted at attracting and retaining small-scale landlords in the private sector. The purpose of this relief is to support the continued participation of small-scale landlords in the rental market, an objective being progressed through Housing for All, the Government’s housing plan to 2030. Landlords are an essential feature of a functioning housing market. Risin…

I move amendment No. 39: In page 36, line 12, to delete “and”. Part 16 of the Taxes Consolidation Act 1997 provides reliefs for investment in corporate trades. These reliefs are the employment investment incentive, EII; the start-up relief for entrepreneurs, SURE; and the start-up capital incentive, SCI. These measures are key incentives which seek to provide SMEs and start-ups with an alternative risk-based source of funding, which helps to support the creation and retention of employment in SMEs across the econom…

I move amendment No. 40: In page 36, line 13, after “ “€15,000,000”,” to insert “and”.

I move amendment No. 41: In page 36, between lines 13 and 14, to insert the following: “(iv) by the insertion of the following subsections after subsection (5): “(6) (a) Where a qualifying company has issued shares in respect of which— (i) relief under this Part applies, and (ii) an entitlement to claim relief under section 600M may apply on the disposal of those shares— then, this section shall apply subject to the following modifications: (I) subsection (1) shall apply with the modifications set out in subsection…

I move amendment No. 42: In page 49, lines 36 and 37, to delete “in the current accounting period or any subsequent accounting period” and substitute “in any accounting period”. Section 36 of the Bill inserts a new Chapter 5 into Part 33 of the Taxes Consolidation Act 1997 to apply new measures to outbound payments of interest, royalties and distributions, including dividends, aimed at the prevention of double non-taxation. This is achieved by way of withholding taxes on outbound payments of interest, royalties and…

I move amendment No. 43: In page 57, to delete lines 6 to 8 and substitute the following: "(3) Section 172C of the Principal Act is amended— (a) in subsection (2), by the insertion of the following paragraph after paragraph (bc): "(bd) subject to subsection (4), a scheme which—". As part of this year's Finance Bill, amendments are being made to provisions of this section relating to the taxation of company distributions to ensure they operate in line with European law. One such amendment is to section 172C of the T…

I move amendment No. 44: In page 57, to delete line 19 and substitute "Schedule 2A,",".

I move amendment No. 45: In page 57, between lines 19 and 20, to insert the following: "and (b) by the insertion of the following subsection after subsection (3): "(4) A person shall not be an excluded person under subsection (2)(bd) in relation to a distribution which is a relevant distribution to which section 817X applies.".".

I move amendment No. 46: In page 58, between lines 8 and 9, to insert the following: "Medical practitioners operating in partnership 38. The Principal Act is amended, in Part 43, by the insertion of the following section after section 1008: "1008A . (1) In this section— ‘enactment’ means a statute or an instrument made under a power conferred by statute; ‘medical partnership’ means a partnership— (a) all of the partners of which are individuals who are medical practitioners, and (b) that is governed by a partnershi…

I thank the Deputies for their comments. The Department of Health has advised that the majority of GPs deliver services as part of a practice, either as partners or practice employees. In its view, the proposed amendment would address a substantial part of the issue, as it understands there are more GPs who are partners than there are those who are employees. Obviously, in the case of an employer-employee relationship, in the same way as in all other such relationships, income tax applies in the normal way. The res…

I move amendment No. 48: In page 59, line 4, to delete “lease” and substitute “finance lease”. These amendments relate to section 38, as amended by the select committee. Section 38 included a number of amendments to the taxation of leased assets in Ireland. Following the publication of the Bill as initiated, a number of issues were raised by stakeholders. The amendments in section 37 of the Bill, as initiated, were aimed at clarifying the rules for calculating taxable income for all lessors and lessees. Stakeholder…

I move amendment No. 49: In page 59, to delete lines 30 to 38 and substitute the following: “(4) (a) Subject to paragraph (b), where, during the lease term, there is a change to the lease term or the amount of the lease payments, then in the accounting period in which the change occurs - (i) the amount of income under subsection (2), or (ii) the amount to be deducted under subsection (3), shall be recalculated. (b) Where the amount of the lease payments is dependent upon any change in facts or matters arising, afte…

I move amendment No. 50: In page 60, between lines 4 and 5, to insert the following: “(b) in section 77, by the insertion of the following subsection after subsection (3): “(3A) In respect of a company that carries on a leasing activity in respect of which the company is within the charge to corporation tax under Case IV of Schedule D, in computing the income from such leasing activity so chargeable, section 76(5)(b) shall not prevent the deduction of yearly interest.”,”.

I move amendment No. 51: In page 62, to delete lines 15 to 28 and substitute the following: “ “(4) Where this section applies and the lessor is a company, the amount to be included in the income of the lessor in respect of a relevant lease shall be - (a) where the relevant lease is a finance lease, the amount of income from such a lease computed in accordance with generally accepted accounting practice, or (b) where the relevant lease is an operating lease, the amount of income from such a lease as would be compute…

I move amendment No. 52: In page 71, line 1, after “ ‘arrangements’ ” to insert “, other than in paragraph (b)(ii) of the definition in this subsection of ‘qualifying subsidiary’,”. Amendments Nos. 52 to 68, inclusive, relate to section 39 which introduced a new section 76E into the Taxes Consolidation Act 1997. The section allows a qualifying financing company, or QFC, to obtain a deduction for interest paid once certain criteria are met. Following publication of the Bill as initiated, stakeholders identified a nu…

I move amendment No. 53: In page 71, between lines 20 and 21, to insert the following: “ ‘indirect qualifying subsidiary’ means, in respect of a qualifying financing company, a company that would be a qualifying subsidiary but for the fact that 75 per cent or more of its ordinary share capital is held directly by an intermediate holding company; ‘intermediate holding company’ means a company 75 per cent or more of the ordinary share capital of which is held directly by a qualifying financing company and whose busin…