We asked Camilla Cullinane, Tax Partner, KPMG, to breakdown the costs and benefits for our members.
There certainly was a lot of detail in yesterday’s Budget. There were various SME-centred tax reliefs and supports which are welcomed. However, while the announcement of a 0.1% increase in PRSI next October 2024 will not come as a surprise, it will add to the costs of business owners along with other costs on the horizon. It felt that the Minister was trying hard to achieve something for everyone, yet it remains to be seen if the benefit of some measures will actually deliver, especially in driving Irish entrepreneurial spirit to its full potential.
Tax measures
A new capital gains tax relief for angel investment in innovative start-ups was announced. The relief will be available to an individual who invests in at least 5% of the ordinary share capital in an innovative start-up SME for a period of at least 3 years. Qualifying investors may avail of an effective reduced rate of CGT of 16%, or 18% if through a partnership, on a gain up to twice the value of their initial investment. There is a lifetime limit of €3 million on gains to which the reduced rate of CGT will apply. Further details will be set out in the Finance Bill and hopefully the applicable conditions will not limit the use and value of this welcomed relief.
The R&D tax credit rate will increase from 25% to 30% in respect of 2024 expenditure, for which claims will be filed in 2025. The first-year payment threshold will be doubled to allow for a claim up to €50,000 to be paid in full in that year.
From 1 January 2024, the existing VAT registration thresholds are being increased modestly to €40,000 for services and €80,000 for goods.
The Accelerated Capital Allowances scheme for Energy Efficient Equipment is being extended for a further two years to 31 December 2025. The temporary universal relief of €10,000 for calculating BIK on company cars will be extended to 31 December 2024. The existing BIK relief of €35,000 on Electric Vehicles will also be maintained up to 2025.
There are also enhancements to the Employment Investment Incentive and Key Employee Engagement Programme.
The age cap on Retirement Relief from capital gains tax on passing on the family business will be extended from 66 to 70 with effect from 1 January 2025. However, a limit of €10 million will then be imposed on the value that will qualify for the relief.
Entrepreneurs’ relief is set to be refocused so that the relief provides better incentives to company founders. It was hoped that we would see incentives to encourage entrepreneurs to remain committed to their businesses for the long haul, such an increasing the entrepreneur relief or extending it to provide access to fund. Unfortunately it appears not this time!
Temporary cost of living package
A €250 million package of temporary supports is being developed to support businesses through current challenges associated with Cost-of-Living pressures, including the increases to the minimum wage.
Details are yet to be published but indications are that a scheme will be established to provide once-off grants to up to 130,000 small and medium-sized firms. The payments will come in the form of tiered grants equivalent to up to 50% of the commercial rates paid by the firms this year. It's expected that payments will be made early in 2024.
For further commentary and insights please visit: https://kpmg.com/ie/en/home/insights/2023/10/budget-2024-tax.html
Finally, we asked the Financial Planning Team at DAVY for their take on the 2024 Budget.
A range of measures was announced today recognising the impact rising costs have on businesses. This support, worth €250 million, includes:
- A dedicated Tax Administration Liaison Committee (TALC)
- The Research and Development (R&D) Tax Credit is being increased from 25% to 30%. The first-year payment threshold is being doubled from €25,000 to €50,000 to "provide valuable cash-flow support to companies engaged in smaller R&D projects”.
- The VAT registration thresholds for businesses increasing from €37,500 for services and €75,000 for goods to €40,000 for services and €80,000 for goods respectively.
- A territoriality / participation exemption for foreign sourced dividends being developed. It is intended that this will be included in Finance Bill 2024.
- The Minister committed to working through the area of interest deductibility.
- The Minister announced an increase in the current project cap on qualifying expenditure in the Section 481 Film Tax Credit from €70 million to €125 million, subject to State aid approval.
- The Minister confirmed that he will be publishing legislation in the Finance Bill to implement the 15% minimum effective tax rate for large companies as provided for under the OECD Pillar Two agreement.
- From 1 January 2024, the minimum wage will increase by €1.40 bringing it to €12.70 an hour.
There are also some changes for investors in SMEs which will be of interest:
- Introduction of a new targeted CGT relief for angel investors. They may avail of an effective reduced rate of CGT of 16% (or 18% if through a partnership), on a gain up to twice the value of their initial investment. There is a lifetime limit of €3 million on gains to which the reduced rate of CGT will apply.
- Enhancements to the Employment Investment Incentive scheme (EII). In particular, from 1 January 2024, the investment limit for relief purposes is now €500,000.
- The Minister committed to examine Revised Entrepreneur Relief with a review to improving it for founders and entrepreneurs.
There are also some significant changes to CGT rules which will impact on the transfer of family businesses.
- Extending the upper age limit for retirement relief from 65 until age of 70. The reduced relief which was available on disposals from age 66 onwards will now apply from age 70.
- From 1 January 2025, there will be a new limit of €10 million (currently there is no limit) on the relief available for disposals to a child up until the age of 70.
For more information visit https://www.davy.ie/.
