Budgetary Measures 

The Minister for Finance (Minister) announced a total budget package of €11bn comprised of budgetary measures of €6.9bn and a package of once off measures worth €4.1bn. The Minister noted that the tax receipts to end-August 2022 were €50bn which is €10bn higher for the same period to end-August 2021. This has allowed the government to introduce measures to ease the increased cost of living and provide business supports. 

Corporation Tax 

The Minister highlighted the boost that corporation tax receipts had provided to the Exchequer, noting a figure of nearly €12bn at end of August. It is expected that these receipts may exceed €20bn this year. To avoid an unwise reliance on the excess receipts, the replenishing of the National Reserve Fund has begun, with an injection of €2bn this year and an intended injection of €4bn in 2023. This is aimed at warding against the future fiscal pressures associated with an aging population, the digital transition and climate change. 

Ireland's corporate tax regime was again noted as a core element of Ireland's economic policy mix. However, it was highlighted that work was continuing to give effect to the Pillar Two minimum effective tax rate. The Minister mentioned that this work will continue alongside a consideration of options for a move towards a territorial corporation tax system. 


It was announced that the Foreign Earnings Deduction will be extended to the end of 2025. 

The Special Assignee Relief Programme will also be extended to the end of 2025 but the minimum income limit for new entrants will be €100,000.

The Knowledge Development Box will be extended for four years resulting in it applying for accounting periods commencing before 1 January 2027. The new effective rate will be 10%. 

Finally, the Finance Bill 2022 will introduce changes to the Research and Development tax credit to align it with new international definitions of refundable tax credits. These measures are expected to be broadly cost neutral. 


A Vacant Homes Tax is being introduced in 2023. This will apply to residential properties that are occupied for less than thirty days in a twelve-month period.  

It was also announced that there will be an extension of the Residential Stamp Duty Refund Scheme until the end of 2025. 

Finally, a new levy of 10% will be introduced on certain concrete products at point of first supply.

Temporary Business Energy Support Scheme 

The Minster announced the introduction of a Temporary Business Energy Support Scheme (TBESS) to assist businesses with the cost of energy over the winter months. This scheme is going to apply to businesses that carry on Case 1 trading activities, are tax compliant and have experienced significant increases in their natural gas and electricity costs. The TBESS will operate on a self-assessment basis under the remit of Revenue and businesses will have a time limit within which they must register and make their claims. 

Consultations & Initiatives 

Amongst the miscellaneous consultations and measures, it was announced on foot of the recommendation made by the Tax Strategy Group that an analysis will commence to consider the introduction of an intermediate or third rate of income tax. This is to align with a medium-term roadmap for personal tax reform. 

A Revenue initiative was announced whereby Revenue will conduct a range of targeted projects including PAYE compliance interventions with a further focus on share schemes and increased debt management activity. It is noted that this will yield additional receipts for the Exchequer. 

A review is going to be undertaken of the REIT and IREF regimes. The review will consider institutional investment in housing and how best housing policy objectives can be supported into the future. 

A working group will be established to review the taxation of funds, life assurance policies and various other investment products. The use of Section 110 regimes will also be reviewed. 

As part of the recognition of Ireland as a location of choice in recent times for multimedia and digital gaming industries, opportunities will be explored to encourage large players in the 'unscripted production sector' to locate here in an effort to boost indigenous businesses.

For further information on Budget 2023, please contact Brian Duffy or your usual William Fry Tax contact.