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2024 RDTC claims Pre-notification requirement
The Finance (No.2) Act 2023 introduced key changes to the Research and Development (R&D) tax credit regime, most notably the increase in the rate of the R&D tax credit (RDTC) rate from 25% to 30%.
The Finance Bill 2023, shortly to be a Finance Act, amends Section 599 TCA 1997 CGT Retirement Relief (“RR”). Broadly speaking, RR provides relief from CGT on the disposal of trading assets or shares in trading companies by persons aged over 55 who have owned the assets for 10 years and worked in the business for at least 10 years, with five of those years being full-time.
Section 599 relates to relief on disposals to a child (as defined in Section 599). At present, if the individual disposing of the qualifying assets is aged between 55 and 65 years of age and the disposal is to a child, full relief may be claimed. The Bill increased the upper age limit from 65 years to 69 years. However, a new cap of €10m will apply to claims for relief where the individual disposing of the assets to a child is aged from 55 to 69. The cap of €10m is not per child, it is a collective cap.
The reduced relief which is available on disposals from age 66 onwards (the existing €3m cap) will therefore now apply where the individual is 70 or older. The table below sets out the new relatively complicated rules:
Age of person disposing to family member | Period to 31 December 2024 | 1 January 2025 onwards |
Age 55 to 65 | No limit on qualifying proceeds | €10,000,000 limit applies |
Age 66 to 69 | €3,000,000 limit applies | €10,000,000 limit applies |
Age 70+ | €3,000,000 limit applies | €3,000,000 limit applies |
If you have any questions in relation to the above, or if you would like to discuss this topic further, please contact a member of the Mazars corporate tax team below:
Staff Member | Position | Telephone | |
Paul Mee | Tax Partner | pmee@mazars.ie | 091 570 137 |
Emma Collins | Tax Director | ecollins@mazars.ie | 091 570 162 |
December 2023
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