Financial Services

Irish Real Estate Funds (IREFs) and Section 110 Companies

The Minster announced that the Revenue Commissioners have identified aggressive activities by some IREF's including the use of excessive interest charges to avoid the payment of tax on profits generated from Irish property. It was announced that a number of anti-avoidance measures are being introduced to counteract these activities, including the introduction of limitations on interest expenses based on debt to property cost and on an income to interest ratio. These measures will be introduced by way of financial resolution and will apply with effect from midnight on 8 October 2019. 

The anti-avoidance provisions in section 110 TCA 1997 are being strengthened to ensure they operate as intended. These changes will be brought in as part of Finance Bill 2019.

Real Estate Investment Trusts (REITs)

A number of amendments have been announced to the existing REIT legislation to ensure that, in the words of the Minister, "an appropriate level of tax" is being collected from the regime. The changes will be introduced by way of financial resolution and will apply with effect from midnight on 8 October 2019.

Bank Levy

The bank levy will be increased from 59% of DIRT in base year 2015 to 170% of DIRT for base year 2017 to protect the €150 million yield in 2019 and 2020. 

For further information on Budget 2020, please contact Brian Duffy or your usual William Fry Tax contact.