Revenue eBrief No. 054/25
03 March 2025
Guidance on Relief for investment in innovative enterprises – Chapter 6A of Part 19 TCA 1997
Relief for investment in innovative enterprises was introduced by section 54 of Finance Act 2024, which inserted Chapter 6A into Part 19 of the Taxes Consolidation Act 1997 (TCA 1997). The relief was commenced by Ministerial order on 1 March 2025.
Revenue has published three new Tax and Duty Manuals in connection with the relief:
- Part 19-06A-03 – Relief for investment in innovative enterprises – Chapter 6A of Part 19 TCA 1997.
- Part 19-06A-02 – Relief for investment in innovative enterprises - Investor’s perspective – Chapter 6A of Part 19 TCA 1997.
- Part 19-06A-01 – Relief for investment in innovative enterprises - Qualifying Company (Certificates of Qualification) – Chapter 6A of Part 19 TCA 1997.
The Relief for investment in innovative enterprises is a Capital Gains Tax (CGT) relief for individuals and allows a qualifying investor avail of a reduced CGT rate of 16% (or 18% in the case of investments made via a qualifying partnership) on a gain arising on the sale of a qualifying investment in a qualifying company subject to certain conditions. The qualifying investment in eligible shares must be made before 31 December 2026. The shares must be held by the qualifying investor for at least 3 years before the disposal.
A qualifying company is a company that holds certificates of qualification which consist of:
- a certificate of going concern, and
- a certificate of commercial innovation.
A company may make an application to Revenue for the certificates of qualification. Revenue will generally consult with Enterprise Ireland, who may in turn consult with a third-party consultant, as part of the certification process.