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Ireland: Finance Bill 2025 introduces DWT exemption for ILPs, with ‘relevant distribution’ tests, outbound payment defensive limits, filing simplifications, and an expanded dividend participation exemption from 2026

Published on: 24 October 2025

Published by a LexisNexis Ireland - Banking & Financial Services expert
Legal News
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Article summary

Although Minister for Finance, Paschal Donohue, did not reference a targeted DWT exemption for investment ILPs in his Budget Day address, the Finance Bill released on 16 October 2025 did include such a measure, sought by several industry bodies on which A&L Goodbody participates. The draft provisions would extend the existing DWT exemptions in section 172C of the Taxes Consolidation Act 1997 (Ireland) (TCA 1997 (IRL)) to encompass ‘relevant distributions’ received by an ILP, or an ‘equivalent partnership’ authorised in the EEA, where specified qualifying conditions are satisfied. Once enacted, the new exemption will apply to relevant distributions made on or after 1 January 2026.

Background to introduction of exemption

ILPs serve as a key Irish holding vehicle for private assets. It is common for ILPs to route investments through several lower-tier investment subsidiaries (SPVs), with SPV profits returned to the ILP by way of dividends. This structure can be adopted for a variety of reasons, including to minimise risk by segregating assets, to meet regulatory requirements, etc. Under existing rules, distributions by the Irish...

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