Category: 3. Business

Main Takeaway

Budget 2027 maintains a fiscally prudent stance with no
broad personal income tax rate cuts, while enhancing
targeted supports for households, business investment
incentives, housing supply and climate action.

The below provides a brief overview of the more relevant
changes that may be of interest to corporate entities followed
by a table providing a general overview of the more significant
tax changes brought in by Budget 2027, across all taxes.

Corporate Tax, Research and Development
(R&D) and Capital Markets

Measures aimed at the corporate sector strategically
reinforce Ireland’s reputation as an innovative base, providing
enhanced incentives for research and supporting capital
market participation for indigenous enterprises.

Impact on Corporate Taxpayers

A central component of the budget’s innovation strategy is
the substantial enhancement of the R&D tax credit. The rate
is being increased from 30% to 35%. This enhancement
provides significant encouragement for both multinational
corporations (MNCs) and indigenous companies to base their
high-value innovation activities in Ireland.

Furthermore, the measure includes vital liquidity and
compliance improvements for smaller claimants.The first-year
payment minimum threshold is being raised from €75,000
to €87,500. This adjustment directly enhances cash flow for
Small and Medium Enterprises (SMEs) engaged in R&D,
accelerating their access to state funding.

Implications for Investors and Investment
Funds

In the financial services sector, stability and technical clarity
are prioritised. The exit tax rate applied to payments made
from Irish funds and equivalent offshore funds to Irish
individual investors has been reduced from 41% to 38%. This
adjustment aims to improve retail participation in investment
funds, as it enhances net returns for non-resident and
domestic investors.

Combined with the unchanged 9% value-added tax (VAT) on
property-related services, Ireland’s fund ecosystem retains
competitive cost structures.

In support of capital markets, a new market cap exemption
threshold of €1 billion is introduced for Irish SMEs and startups
trading on regulated markets. For companies falling below
this threshold, the standard 1% stamp duty charge paid on
share transactions will no longer apply. The SME marketcap
threshold stamp duty exemption is aimed at attracting
increased equity financing for growth companies listed on
regulated markets, bolstering liquidity and investor appetite.

Entrepreneurial Incentives and Capital
Gains

To stimulate entrepreneurial activity and reward risk-takers,
the Capital Gains Tax (CGT) Revised Entrepreneur Relief has
been significantly strengthened. The overall lifetime limit on
gains eligible for the reduced 10% CGT rate is increased
from €1 million to €1.5 million. This 50% increase applies to
qualifying disposals made on or after 1 January 2026. This
policy signals a strong commitment to supporting successful
founders and incentivises them to reinvest their capital within
the Irish economy, thereby promoting further start-up creation
and economic dynamism.

In support of capital markets, a new market cap exemption
threshold of €1 billion is introduced for Irish SMEs and startups
trading on regulated markets. For companies falling below
this threshold, the standard 1% stamp duty charge paid on
share transactions will no longer apply.

This measure is positioned as essential for enhancing the
growth prospects of homegrown businesses, particularly
those seeking to secure funding or scale internationally. The
Key Employee Engagement Programme (KEEP) has also been
extended until the end of 2028.

Conclusion

Although from a personal income tax perspective Budget
2027 has a much more targeted and measured approach
to what we’ve seen in previous years, the enhancements
to R&D incentives, fund taxation and SME reliefs should
hopefully lower effective tax burdens for corporates and
investors, foster greater deal activity in growth sectors
and prop up Ireland’s positioning as a tax-efficient hub for
innovation finance.

The below table provides a brief summary of the pertinent
tax changes brought in by Budget 2027. We now wait for
the publication of Finance Bill 2026, to see exactly how
these measures will be implemented.

Tax Area	Measure	Key Change/Rate	Effective Date (or Period)	Potential Impact / Client Action
Corporate & SME Tax	Directly or indirectly, individually or in aggregate	Treated as if itself on the Entity List	Same restrictions as parent entity apply	Same restrictions as parent entity apply
	Unlisted foreign entity owned ≥ 50% by MEU List party	Directly or indirectly, individually or in aggregate	Treated as if itself is an MEU	Same restrictions as parent MEU entity apply
	Unlisted foreign entity owned ≥ 50% by an SDN*	Directly or indirectly, individually or in aggregate	Treated as if itself an SDN*	Same restrictions as the SDN owner
Financial Services	Exit Tax (Investment Funds)	Reduced rate on fund payments to individuals	41% to 38%	Aims to encourage greater retail participation by Irish individuals in domestic investment funds.
	SME/Start-up Stamp Duty Exemption	New Market Cap Threshold in respect of shares traded on regulated markets.	Up to €1 billion (Exemption applies)	Supports capital market liquidity and growth for indigenous SMEs and start-ups.
Indirect Taxes (VAT & Excise)	VAT on Hospitality/Hairdressing	Reduced rate introduced	13.5% to 9% (from 1 July 2026)	Significant support for the services sector, aiding more than 150,000 jobs facing cost pressures.
	VAT on Gas and Electricity	Reduced rate extension	9% extended until 31 Dec 2030	Provides long-term certainty and relief on essential energy costs for households and businesses.
	Carbon Tax (Auto-Fuels)	Increased rate per tonne of CO2	€63.50 to €71.00 (from 8 Oct 2025)	Immediate increase in the cost of petrol and diesel; future cost increases for home heating fuels (May 2026).
	Tobacco Excise Duty	Increase per packet of 20 cigarettes	+50 cent (from 7 Oct 2025)	Will push the cost of a popular packet of 20 cigarettes towards €19.
Housing Supply & Development	VAT on New Apartments	Reduced sales rate	13.5% to 9%	Direct reduction in construction costs, intended to lower the final price of new apartment units.
	Derelict Property Tax (DPT)	New tax to replace Derelict Sites Levy	Rate not < 7%=”” of=”” market=”” value=”” (implementation=”” />	Allows Revenue to enforce a minimum 7% annual charge on the market value of vacant land.
Employment & Global Mobility	SARP Minimum Income Threshold	Increased threshold	€125,000 (from 2026)	Requires review of all current/planned expatriate assignments; employees below €125k will cease to qualify for the relief.
	Foreign Earnings Deduction (FED)	Increased maximum relief; Scope widened	€50,000 (from 2026) and now includes Philippines & Turkey	Improves competitiveness for deploying employees to/from expanded market list (Philippines, Turkey).
	Company Car BIK Relief (€10k OMV reduction)	Relief Tapering Schedule	€10,000 (2026); €5,000 (2027); €2,500 (2028); Abolished (2029)	Requires immediate review of corporate fleet policies due to rapid BIK relief withdrawal starting in 2027.
Personal Tax (Income & USC)	USC 2% Rate Band Ceiling	Increased by €1,318 (to €28,700)	1 January 2026	Provides marginal tax relief for middle-income earners; protects minimum wage earners from moving into the top USC rate band.
	Rent Tax Credit	Extended (Value remains €1,000 p.a.)	Extended to end of 2028	Confirms continued cost-of-living support for eligible tenants for three additional years.
	Mortgage Interest Relief	Extended (reduced value in final year)	Extended for 2 years (2025 and 2026)	Provides temporary support for homeowners but note the relief value diminishes in 2026.

The waning hours of Amazon Prime Day—or Prime Big Deal Days—are the star of the show right now, but maybe you want to go shopping somewhere else. Whatever your reasoning, fear not! Plenty of other stores, big and small, are hosting sales alongside Amazon through the end of today. Everything below is hand-tested by WIRED, and doesn’t have to be bought on Amazon. You do you.

If you want to take a gander at the rest of our Amazon Prime Day coverage, updated through the end of the event tonight at 11:59 am ET, you can find it all right here.

Updated October 8, 2025: We’ve added new deals from Slumber Cloud and The Company Store.

WIRED Featured Deals:

Cozy Earth: Up to 25 Percent Off Sitewide—Use Code WIRED

Ask almost anyone on the WIRED Reviews team about their opinion on Cozy Earth, and it’ll be positive. The company makes supremely soft, silky, and comfortable bamboo products, ranging from bedding and linens to pajamas and hoodies. The Cozy Days sale means you can save up to 25 percent off nearly everything on the website.

Backcountry 70 Percent Off Flash Sale

Backcountry is offering up to 70 percent off select outdoor gear and apparel. The sale includes biking, skiing, and climbing gear.

Best Buy’s Techtober Sale

Want some great deals on tech gear but are avoiding Jeff Bezos? Best Buy might not be much better, spiritually, but the retailer is offering a few deals during its Techtober sale that we haven’t seen elsewhere. Techtober lasts until Sunday.

Bookshop.org Anti-Prime Sale: Free Shipping

It’s easy to buy books from big-box stores, but Bookshop.org helps support authors and local bookstores. Right now, you can get free shipping on all orders during its Anti-Prime Sale. You can check out popular books here, or might I recommend Everything Is Tuberculosis by John Green? (I just started it and I had to force myself to put it down until the weekend.)

Solo Stove Two-Day Sale

Solo Stove makes a lot of solid gear, including pizza ovens and its well-known fire pits. Right now, nearly everything is on sale, and it’s a great time to pick something up ahead of the colder and cozier months.

Chirp Wheel XR (3-pack) for $104 ($26 off)

The Chirp Wheel XR helped our tester Hannah Singleton with her tech neck woes. You’ll get multiple different sizes with the three- or four-pack, which are specially designed to help work out kinks and tension in various points of your body. It’s important to start slowly, ease into it, and only use the wheel for small amounts of time to start. But now that she’s had practice, Singleton says she can’t imagine living life without her Chirp wheels.

Lelo: Up to 40 Percent Off + Free Gift

We like a lot of Lelo sex toys here at WIRED, and many of them are discounted for the store’s “Prime Time for Pleasure” sale. There are options for all sorts of bodies and partner situations, and purchases over $199 get a free Sona 2 Travel vibrator.

Brooklinen Big Deals: 15 Percent Off Sitewide

Brooklinen makes darn fine bedding and linens, and right now the whole site is 15 percent off. Similar to Cozy Earth, everyone on the WIRED Reviews team has great things to say about the Brooklinen gear they’ve tested. Here are some of our faves.

Slumber Cloud Fall Sale: 20 Percent Off

Slumber Cloud makes some of my all-time favorite cooling bedding, including fantastic cooling sheets and even a cooling travel pillow. You can shop up to 20 percent off the site right now for its fall sale.

The Company Store Comfort Days Sale: 25 to 40 Percent Off Sitewide

The Company Store makes a ton of fantastic bedding, from sheets for every season to luxe down comforters and even a great Serene Foam mattress topper. (Serene foam is like memory foam, but traps less heat, so you’ll love this if you want a softer bed.) The shop is running a sitewide sale of 25 percent off orders over $100 (use code COMFORT25), and some items, like the fantastic linen sheets, are 40 percent off.

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Elon Musk has agreed to settle a $128m (£100m) lawsuit brought by four former top executives at Twitter, now X, over unpaid severance when he took over the company.

The executives, who include former chief Parag Agrawal, argued that Mr Musk fired them “without reason” after he bought Twitter in 2022 and denied them severance payments.

“The parties have reached a settlement and the settlement requires certain conditions to be met in the near term,” attorneys for the plaintiffs wrote in a court filing last week. They did not disclose the terms of the settlement.

The suit, filed last year, is one of several legal challenges over unpaid severance for workers who were laid off after Musk took over.

Lawyers for the former Twitter executives, and for Mr Musk and X, did not immediately respond to requests for comment on the settlement.

The former top brass – Mr Agrawal, former chief financial officer Ned Segal, former chief legal officer Vijaya Gadde and former general counsel Sean Edgett – contended in their lawsuit that they are owed one year’s salary and stock awards, under a years-old severance plan.

They also said Musk’s move was part of a pattern of refusing to pay former staff what they were due.

In August, Mr Musk and X agreed to settle a separate lawsuit filed by roughly 6,000 former rank-and-file Twitter employees who argued they were owed $500m in severance pay.

Mr Musk purchased Twitter in 2022 for $44bn, after initially trying to back out of his offer. After the acquisition closed, he immediately moved to fire top leaders at the company, including the four executives. Mr Musk slashed Twitter’s workforce by more than half.

In their lawsuit, the former top officials contend that Mr Musk was frustrated about being forced to complete the purchase and that the billionaire falsely accused them of misconduct to push them out.

By Young Jin Kim & Bart de Gouw

 

It is widely accepted that cross-border related-party debt can be used by multinational enterprises (MNEs) to shift profits out of a country. In the New Zealand context this led to the introduction of the Restricted Transfer Pricing (RTP) rules and the requirement to disclose inbound cross-border intercompany loans with a value of more than NZD10M to Inland Revenue in the BEPS Disclosure Form (this disclosure requirement has since been amended effective from the 2025 income year with taxpayers just required to hold a copy of the necessary information).

In recent years, the International Revenue Strategy (IRS) team at Inland Revenue has observed considerable behavioural change by foreign-owned MNEs with the introduction of additional equity and/or reducing related-party debt financing. This behavioural change has been attributed to the introduction of the RTP rules and a greater focus on financing by the Inland Revenue (via targeted campaigns, risk reviews and audits).

The past five years has seen a highly volatile interest rate environment, with historic lows in the Official Cash Rate in the 2020 and 2021 years, a rapid increase in 2022 and 2023, and a declining rate since the middle of 2024.  This level of volatility has meant that taxpayers should have been regularly reviewing intercompany financing arrangements to ensure that the behaviour of the parties to the loans, the terms and conditions of loans, and the interest rate have all remained arm’s length.  With the increases in the interest rates applying to the most recently filed 2023 and 2024 tax returns coupled with the Inland Revenue stepping up its audit activity more generally, we are expecting intercompany loans and financing to become a key area of focus for Inland Revenue.  This is starting to come to fruition with the number of risk reviews and audits focusing on intercompany financing increasing.

Risk assessment – Are you a green light or red light?

Now is an opportune time for taxpayers to reflect on their intercompany loans and key risk areas that could be challenged by Inland Revenue. To help with this, we have summarised 9 risk factors when it comes to intercompany loans.

1. The loan is over NZD10m at any time during the income year. RTP rules will apply to the loan and an analysis of the rules will be necessary, which can lead to material denial of interest deductibility as the borrowers’ credit rating may be adjusted and certain loan terms and conditions disregarded.
2. No documented loan terms. Loan agreements are important – this will be the starting point for any Inland Revenue review. In the absence of a valid agreement, Inland Revenue may seek to imply (unfavourable) terms and any pricing analysis conducted to support the interest rate will not have strong basis.
3. Loan agreements that do not clearly state what the arrangement is and what the key purpose of the funds advanced is.
4. The arrangement is non-commercial or contains ‘exotic’ features such as subordination, interest deferral of more than 12 months, or has a term of more than five years. Under the RTP rules, certain exotic terms cannot be priced into the interest rate.
5. Using a fixed interest rate for a revolving credit facility loan (that can be drawn down and repaid by the borrower) or a floating interest rate for a fixed term loan (the reset of an interest rate on a fixed term loan is likely a trigger point requiring a retesting the application of the RTP rules).
6. The loan has been extended, renegotiated, or renewed in the past year. This could make a big difference to the deductible level of interest as the interest rate environments change very quickly and these events also require retesting of the application of the RTP rules.
7. Has the loan been reset at a higher interest rate?  Is this what a third-party borrower would do, i.e. is the behaviour of the parties demonstrably arm’s length?
8. Does the borrower have a high debt percentage?  Greater than 40% is considered high risk for borrowers with a cross border related party borrowing of more than NZD10m.  Similarly, borrowing from related parties in low tax jurisdictions (<15% tax rate) is also a risk factor as set out in the RTP rules.
9. Be mindful of interest gross up clauses – any additional interest paid under a gross-up clause also needs to be arm’s length.

Update to Inland Revenue’s administrative guidance on small value loans

Inland Revenue annually publishes an administrative guidance for small value loans (i.e., for cross-border associated party loans for up to NZD10M principal). This administrative guidance may be applied to cross-border associated party loans.

Inland Revenue has historically provided an interest rate margin (over a relevant base indicator) that it considers to be broadly indicative of an arm’s length rate, in the absence of a readily available market rate for a debt instrument with similar terms and risk characteristics.  The most recent change to the interest margin has also introduced (without explanation or consultation) a change in approach to make the interest rate margin backward looking only and in our view, reduces the practical application of this otherwise widely used administrative guidance.  The current interest rate margin in the guidance is 250 basis points over the relevant base rate and applies for the period 1 July 2024 to 30 June 2025. There is now no equivalent guidance for interest rates for the year to 30 June 2026.  We will continue to provide updates on any developments on the administrative guidance.

Next steps

If any of the above risk factors concern you please contact your usual Deloitte advisor or one of our award winning transfer pricing team to help navigate the issues.

By Amy Sexton & Robyn Walker

 

The prospect of a significant sum of money lying dormant and unclaimed will motivate many to search the Inland Revenue’s unclaimed money database, especially when media coverage draws attention to its existence. The recent Taxation (Annual Rates for 2025–26, Compliance Simplification, and Remedial Measures) Bill (the Bill) proposes changes aimed at simplifying the management of unclaimed money by Inland Revenue, with the intention of making it easier for rightful owners to make claims.

What is ‘unclaimed money’

Unclaimed money are funds held by an individual or organisation (such as bank, solicitor, utility company, life insurer, employer, other business) where the rightful owner cannot be located. After a specified period of time passes without contact, these funds are classified as “unclaimed” and transferred to an administrator. The required time period varies depending on the type of funds involved.

While Inland Revenue is widely recognised for administering unclaimed money, not all categories of unclaimed funds fall under its responsibility, a raft of options are outlined on The Treasury website.

What are the proposed changes?

Additional information

Currently the Unclaimed Money Act 1971 puts the following obligations on holders of unclaimed money:

1. A holder must make reasonable efforts to locate the owner of money that is, or will soon become, unclaimed money and to communicate with the owner concerning the money.
2. A holder of money that pays the money to the Commissioner as unclaimed money must provide to the Commissioner, with or before the payment and in a form acceptable to the Commissioner, the information relating to the owner and the money that is in the possession or control of the holder and is readily available to the holder, including—

a. the source, and history of the accrual, of the amount

b. the identity and whereabouts of the owner

c. the source of the owner’s entitlement to payment of the money.

Under the Bill. when transferring unclaimed money, holders will be required to provide Inland Revenue with more detailed information to assist in identifying the rightful owner. The new legislation will read as follows:

1. A holder must make reasonable efforts to locate the owner of money that is, or will soon become, unclaimed money and to communicate with the owner concerning the money.
2. A holder of money that pays the money to the Commissioner as unclaimed money must provide to the Commissioner, with or before the payment and in a form acceptable to the Commissioner, the information relating to the owner and the money that is in the possession or control of the holder and is readily available to the holder, including—

a. the source, and history of the accrual, of the amount

i. the full name, date of birth, and tax file number of the owner

ii. the address and contact details of the owner

b. the whereabouts of the owner

c. the source of the owner’s entitlement to payment of the money

d. where applicable, the number of the account where the money is held, the date the account was opened, and the date of the owner’s last interaction with the account.

It is important to note that under both the current and proposed legislation, the information needs to be in the “possession or control” and “readily available” to the holder. With more data points being required upfront there will be a need for businesses dealing with unclaimed money to give thought to whether new systems and processes are required to efficiently extract information, particularly if it is spread across different information sources.

20 year time bar

In 2021 a 25 year time bar was introduced for unclaimed money administered  by Inland Revenue. The proposal is to reduce this time bar to 20 years (which is still a very long time!). If money remains unclaimed after the time bar, it will be removed from the unclaimed money list and transferred to the Crown. 

Why make changes?

Currently, claimants often face challenges in proving ownership of unclaimed money, leading to considerable correspondence with Inland Revenue. These proposed changes are intended to streamline the process for all parties involved. For context, in the 2023/24 year Inland Revenue received 23,000 claims for unclaimed money but approved only 4,300 claims, amounting to $36.5m, with over $0.5b remaining unclaimed.

These proposed changes are scheduled to take effect from 1 April 2026.

If you believe you may have a claim to unclaimed money and are unsure how to establish ownership, please contact your usual Deloitte advisor for assistance.