One of the first things Sarah Paulson’s character does in the new trailer for “All’s Fair” is call Kim Kardashian’s character a vulgar slang term for female genitalia. One of the last things she does is call her a “whore lawyer.”…
Kevin Hall made a career out of figuring out what’s wrong with the way we eat. So, you may be surprised to discover that he isn’t one of those “clean” eating types who shun all packaged foods.
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).
India’s IPO bull run is being driven partly by mom-and-pop investors
India’s ravenous appetite for stock market investing has sparked a fundraising gold rush in Asia’s third largest economy, with its booming initial public offerings (IPO) market undeterred by trade tariffs or global uncertainties.
Major companies – from global co-working firm WeWork India and South Korean conglomerate LG Electronics’ India arm to financial services giant Tata Capital – have raised record-setting amounts of money just this week, offering their shares to investors through IPOs.
Unlike the secondary markets, where investors buy and sell existing stocks of companies, IPOs are used by privately held firms to sell their shares to investors for the first time, and debut on the public markets.
Some 79 companies raked in $11.5bn (£8.58bn) in the first nine months of 2025, while a string of other issues in the final three months of the year is expected to bring in another $10-11bn, pushing India’s IPO market to more than $20bn this year, according to investment bank Kotak Mahindra Capital Company. And this is not counting the fundraising done by India’s small and medium-sized enterprises.
Companies operating in a wide range of sectors including new-age tech firms, e-commerce majors, retail, infrastructure and healthcare players are tapping the IPO market.
“This has given Indian investors the breadth [of investment opportunities] that’s not seen in other countries,” V Jayasankar, managing director at Kotak Mahindra Capital Company, told the BBC.
“Apart from institutional money, systematic investment plans [or fixed monthly contributions] by mom-and-pop investors in mutual funds has kept flows into IPOs robust,” Mr Jayasankar said.
Getty Images
Major companies such as LG Electronics India raised money through IPOs this week
Besides high demand for new investment opportunities, the market is on fire also because India’s growth over the past decade has birthed a strong pipeline of companies across diverse industries that have reached a certain scale and maturity, according to Abhinav Bharti, head of India equity capital markets at US investment banking giant JP Morgan.
“This is just the start of the trend, and we should see India to be a regular $20bn IPO market on an ongoing basis, if not higher,” Mr Bharti said on the company’s YouTube channel.
But while this wave of new share offerings signals a maturing of India’s investing landscape, the euphoria also demands caution, experts say.
“There’s a lot of exuberance. Investors need to be selective and study the financials of the companies they choose. They must not invest blindly,” says Kranthi Bathini of WealthMills Securities.
The IPO frenzy has hit a fever pitch even as Indian stock markets overall have delivered lacklustre returns to investors.
India’s benchmark Nifty-50 index of its largest and most liquid companies has clocked barely 6% this year, while returns from indices tracking small and mid-sized firms are negative.
Besides concerns about worsening global geopolitics and US President Donald Trump’s 50% tariffs on India, expensive share valuations have worried analysts.
But ironically, this could be contributing to the high interest in debuting companies.
“Investors currently see IPOs as a better place to make returns because of the chance of a 15-20% pop in the stock price on listing,” said Mr Jayasankar.
However estimates suggest that half of the IPOs that have debuted this year are trading below their listing price. Kotak’s own analysis shows that only 43 of the 79 companies that listed this year have given positive returns.
Mr Jayasankar says this could partly be because they were mis-priced (sold expensive) or because the overall market sentiment is low.
Also, the majority of the companies hitting the markets in the first nine months were smaller firms, which tend to be more volatile.
“The last quarter of the year tends to be skewed towards larger or better-quality companies hitting the market,” Mr Jayasankar said.
Getty Images
Millions of young Indians are putting money into the markets using online apps
While Indians have been lapping up new issues, there has been a distinct lack of interest in these IPOs from foreign investors, who’ve sold over $20bn in Indian equities this year.
“Global investors are in wait-and-watch mode,” said Mr Bathini. “India has gone from being the most favoured nation to the least favoured nation for them in a matter of months, because of tariffs and other uncertainties.”
Their lack of participation in the IPO market reflects an overall reduction in portfolio funds to India, he said.
This, if anything, is an obvious signal that domestic mom-and-pop investors are getting swayed by euphoria rather than fundamentals.
“There is an entire industry working to first build and then maintain this mood,” writes economics commentator Vivek Kaul in a piece for Mumbai Mirror newspaper. This includes investment bankers, analysts at stock brokerages and fund managers, he says.
The frenzy is fun, says Mr Kaul, and a game of perceptions and hype, but “not for turning a modest investment into lasting financial security”.
But Indian investors do not appear to be in a mood to listen.
With companies such as Walmart-backed PhonePe, India’s largest mobile telecoms giant Jio and unicorns [tech start-ups valued at over $1bn] such as Groww and Meesho hitting the markets in the coming months, India’s IPO party is likely to continue, at least for some more time.
Follow BBC News India on Instagram, YouTube,X and Facebook.
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.
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.
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.
Loan agreements that do not clearly state what the arrangement is and what the key purpose of the funds advanced is.
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.
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).
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.
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?
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.
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.
APA Corporation Provides Third-Quarter 2025 Supplemental Information and Schedules Results Conference Call for Nov. 6 at 10 a.m. Central Time APA Corporation
APA Corp (APA) Reports Q2 2025: Improved Permian Efficiency and Steady Dividend Payouts Yahoo Finance
APA Corporation Provides Third-Quarter 2025 Supplemental GlobeNewswire
Are APA’s (APA) Rig Reductions a Sign of Efficiency or a Shift in Growth Priorities? simplywall.st
Analysts Cite Return-of-Capital and Egyptian Gas Growth as Catalysts for APA (APA) Insider Monkey