CCH Corporation Tax IE: 2025.8.2

Prerequisites

Surrender Losses and Claim Losses

As per the CT1-V25 schema changes recommended by ROS, changes recommended for the confirmation of Surrender Losses and Claim Losses section under Company Details page of Group section. See the following screenshot highlighted red box.

The new fields are listed below: 

1. Indicate, by inserting X in appropriate box, if any surrender of relevant leasing losses or capital allowances arises in respect of machinery or plant.
2. Indicate, by inserting X in appropriate box, if any claim of relevant leasing losses or capital allowances arises in respect of machinery or plant.

 

Details of relevant leasing losses or capital allowances surrendered in respect of machinery or plant

This change affects any company that is surrendering losses to another company under the group relief provisions. The purpose of this new element is to ensure that the surrendering company explicitly confirms that all statutory requirements for a valid surrender of losses have been satisfied at the time of filing.

 A couple of new fields have been introduced under ‘Surrender of Losses, etc’ sub-heading in Company Details page, under Group, to handle this element. Under this sub-heading, one needs to select the check box ‘Insert X inappropriate box, if any surrender of relevant leasing losses or Capital allowances in respect of machinery Plant’ for mandatory confirmation for the surrender to be considered valid within the ROS system.

Related link below this section, need to be clicked to open the popup to provide relevant details against the ‘leasing losses or capital allowances surrendered’. Details of the following fields need to provide for the same.

Following are the fields that you need to fill in the popup

1. Name of company to which loss/allowance is surrendered
2. Irish Tax Reference Number
3. Nature of Relief
4. Amount Surrendered
   a)      Clause I activities
   b)      Clause II activities
5. Clause IIA activities
   a)      Clause III activities
   b)      Clause IV activities
6. Clause IVA activities
7. Clause IVB activities

Details of relevant leasing losses or capital allowances claimed in respect of machinery or plant

The primary change addressed is the introduction of a new mandatory confirmation field: claimLossesConfirmation. This field is designed to improve data accuracy, streamline automated validation, and ensure that a filer’s intention to claim loss relief is explicitly declared.

The claimLossesConfirmation field serves as a master control for all forms of loss relief being actively claimed within the return. Its purpose is twofold:

1. For the Filer: It acts as a crucial checkpoint, forcing the filer to confirm that a conscious decision has been made to utilise losses in the return being filed. This helps prevent errors where loss figures are entered in the computations, but the actual claim for relief (e.g., carry-back) is inadvertently omitted.
2. For Revenue: It enables ROS to perform more robust validation. If 'Yes' is selected, the system will expect to see corresponding data entered in the relevant loss relief sections of the return (e.g., Section 4 for trading losses

A couple of new fields have been introducing under ‘Claim to Losses, etc’ sub-heading in Company Details page, under Group to handle this element. Under this sub-heading, one needs to select the check box ‘Insert X inappropriate box, if any claim of relevant leasing losses or Capital allowances arises in respect of machinery or plant’ for mandatory confirmation for the ‘claim to losses’ considered valid within the ROS system.

Related link below this section, need to be clicked to open the popup to provide relevant details against the ‘leasing losses or capital allowances claimed. Details of the following fields need to provide for the same.

Following are the fields that you need to fill in the popup

1. Name of company to which loss/allowance is claimed
2. Irish Tax Reference Number
3. Nature of Relief
4. Amount Claimed
   a)      Clause I activities
   b)      Clause II activities
5. Clause IIA activities
   a)      Clause III activities
   b)      Clause IV activities
6. Clause IVA activities
7. Clause IVB activities

De Minimis Aid

S299 Leases agreed with Corporate Lessees

The CT1-v25 schema now incorporates enhanced reporting requirements for Section 299 (S299) Leases where the Lessee (the company leasing the asset) is a corporate entity.

S299 Leases refer to arrangements where, despite not owning the asset, your company (the lessee) is contractually obliged to maintain the machinery or plant and bear the cost of its wear and tear. In such "relevant leases," your company may be deemed to have incurred the capital expenditure for tax purposes

Under Company Details page, a new link ‘S299 Leases agreed with Corporate Lessees’ has been introduced to handle this operation. On clicking it, system will redirect you to the relevant page for proper entries. Following are the important fields for consideration.

Following are the attributes we cover in this section:

1. If the company is making a claim, or claims, within the meaning of section 299(5)(h)(ii) in respect of a relevant lease, or leases, and give the following details in respect of each such relevant lease
2. Lesee Name
3. Is the Lesee Tax Resident in Ireland
4. If Yes, please enter the Tax Reference number
5. If No, please select the county of Incorporation/Residence
6. Associate Enterprise
7. Open Market Value of Leased Asset at Outset
8. Lease Income arising under S299(4)
9. Actual Lease payments receivable
10. Capital Allowances Forgone
11. Total claimed under S299(5)(h)(ii) in respect of a relevant lease or leases
12. Is the Lease Income Arose in the Course of a Trade

S299 Leases with Corporate Lessors

This update to the CT1-v25 schema introduces specific fields to capture details for leases of machinery or plant where Section 299 of the Taxes Consolidation Act 1997 applies, and the lessor is a corporate entity.

Under Company Details page, a new link ‘S299 Leases agreed with Corporate Lessors’ has been introduced to handle this operation. On clicking it, system will redirect you to the relevant page for proper entries. Following are the important fields for consideration.

Following are the attributes we cover in this section:

1. If the company is making a claim, or claims, within the meaning of section 299(6)(b)(ii) in respect of a relevant lease, or leases, that is subject to the joint agreement referred to in that paragraph and give the following details in respect of each such relevant lease
2. Lessor Name
3. Is the Lessor Tax Resident in Ireland
4. If Yes, please enter the Tax Reference number
5. If No, please select the county of Incorporation/Residence
6. Associate Enterprise
7. Open Market Value of Leased Asset at Outset
8. Lease Payment Deductible under S299(3)(a)
9. Actual Lease payments payable
10. Deemed Total Capital Expenditure under Section 299(3)(b)
11. Capital Allowances in Period
12. Total claimed under S299(6)(b)(ii) in respect of a relevant lease or leases

S299 Leases agreed with Individual Lessees

ROS introduces specific fields for corporate lessors who have entered into "relevant leases" of machinery or plant where the lessee is an individual. This change is applicable if your company (the lessor, filing the CT1) has a lease agreement for machinery or plant with an individual lessee.

Under Company Details page, a new link ‘S299 Leases agreed with Individual Lessors’ has been introduced to handle this operation. On clicking it, system will redirect you to the relevant page for proper entries. Following are the important fields for consideration.

Following are the field we cover in this section:

1. If the company has made an election(s) under Section 299(3)(b) in respect of a relevant lease, or leases. Where a joint election has been made, please provide the following
2. Number of Leases in respect of which an election was made.
3. Are any Lessees Associated Enterprises of the Lessor? [Y/N]
4. Total Lease Income Arising Under section 299(4)
5. Indicate, by inserting X in the appropriate box if the Lease Income Arose in the Course of a Trade or otherwise
6. Total Actual Lease Income Receivable
7. Total Open Market Value of Affected Leased Assets at Outset
8. Total Capital Allowances Foregone

Transfer Pricing

This update to the CT1-v25 schema introduces a new field, chargeablePeriodUnder835DA, to accommodate reporting requirements related to Section 835DA

This change is relevant if your company is part of a multinational enterprise (MNE) and engages in wholesale distribution, sales agency, or commissionaire activities involving tangible goods that fall within the scope of OECD Pillar One – Amount B. This framework aims to simplify transfer pricing rules for routine activities, ensuring profits are taxed where economic activities occur.

A new section under Transfer Pricing page of Company details (navigation Company Details > Transfer Pricing), you will find this newly introduced field.

Extract from Accounts

Irish Investment and Other Income

Several changes have been made under Irish Investments and other income. Following are listed below:

1. Leasing profits
2. Qualifying financing Companies
3. Digital Games Interim Corporation Tax
4. Clawback in respect of Research & Development Activities

Leasing Profits

The update of Leasing Profits standardizes how corporate lessors (companies that lease out assets) should calculate and report their taxable profits from leasing activities.

If your company is involved in leasing machinery or plant, the way your leasing income is recognised for tax purposes may have changed. The update aims to align the tax treatment of certain leases more closely with their accounting treatment, particularly for "relevant leases"

In our application, a sets of fields have been introduced in the Leasing Profits Page under Irish Investment and Other Profits menu. Once one open the page, the system will allow you to put the values in Current Year column. Next year onwards, the system will fetch the ‘Last Year’ data.

Qualifying Financing Companies

CT1-v25 schema introduces a new concept of a "Qualifying Financing Company" (QFC), as defined by recent tax legislation. This is relevant for companies acting as an intermediary for financing within a group. The changes are designed to provide tax relief for certain interest payments, subject to strict conditions.

In our application, a new page Qualifying Financing Company has been introduced under Irish Investment and Other Income menu. It contains 3 sections.

In top section you need to provide information related to income from Unmatched Loan, Gross & Net Qualifying Income.

Following are the attributes:

1. Income from Unmatched Loans or Unmatched Portions of Loans
2. Gross Qualifying Financial Company Income
3. Gross Qualifying Financial Company Income (net)

Here system will calculate and provide the values in Gross & Net Qualifying Income fields, which are editable in nature. Following is the calculation hint for these fields

Gross Qualifying Financial Company Income  = Interest Receivable   +   Income from Unmatched Loans or Unmatched Portions of Loans  

Gross Qualifying Financial Company Income (net) = Gross Qualifying Financial Company Income   -   External Loan Interest Deductible

Next section is to provide list of Loan Recipients details including their name, tax, country, principal loan amount, balance amount etc.

Lastly, we have a link at the bottom of the screen ‘Enter details of each matched recipient in relation to this loan’ to provide relationship and load details of each matched recipient, against the loan. By default the link is not activated. One needs to select any Loan Recipients from the above list and press the ‘Edit’ button to fetch the details, then only the link will be activated.

Associated fields for this section is:

1. If the company is a Qualifying Financing Company within the meaning of section 76E.
2. External Lender Name
3. If the External Lender is Irish Resident, please enter the Tax Reference number
4. If the External Lender is not Irish Resident, please enter the country of incorporation/residence
5. External Loan Principal Amount
6. External Loan Balance Outstanding
7. External Loan Interest Deductible

Digital Games Interim Corporation Tax

A new section has been introduced where specific fields to facilitate claims for the Digital Games Interim Corporation Tax Credit. This credit, designed to support the development of qualifying digital games in Ireland. It offers a substantial refundable tax credit of eligible expenditure incurred in the design, production, and testing of a qualifying digital game.

1. For section under 481A(19), following fields now being added
2.  (A). Treated as an overpayment of tax, for the purposes of section 960H, as set out in section 481A(22)(a) TCA 1997? If yes, please include the amount or any portion of such amount
3. If yes, please state the amount A(i). The amount of the overpayment as set out in (x)(A) which is to be offset against the company's corporation tax payable for the accounting period for preliminary tax purposes under section 481A(22F).
4. B. Paid to the company by the Revenue Commissioners, as set out in section 481A(22)(b) TCA 1997. If yes, please state the amount or any portion of such amount.
5. If Yes, please state the amount

Whereas for Section under 481A(20), two more fields have been added along with the previous block. So, in this page the newly introduced fields are as follows:

1. Accounting period in which expenditure incurred begin date
2. Accounting period in which expenditure incurred end date
3. (A). Treated as an overpayment of tax, for the purposes of section 960H, as set out in section 481A(22)(a) TCA 1997? If yes, please include the amount or any portion of such amount
4. If Yes, please state the amount
5. A(i). The amount of the overpayment as set out in (x)(A) which is to be offset against the company's corporation tax payable for the accounting period for preliminary tax purposes under section 481A(22F).
6. B. Paid to the company by the Revenue Commissioners, as set out in section 481A(22)(b) TCA 1997. If yes, please state the amount or any portion of such amount.
7. If Yes, please state the amount

      

                    

Clawback in respect of Research & Development Activities

The clawback mechanism for Research & Development (R&D) Tax Credits. It's designed to ensure proper reporting when a previously claimed R&D tax credit is subsequently deemed not properly due. This is crucial for maintaining the integrity of the R&D incentive scheme.

Following two new attributes have been introduced for handling additional asks, below the existing section

1. Amount taxable Case IV Sch.D (Sec. 766C(10)(c)(i))
2. Amount taxable Case IV Sch.D (Sec. 766D(9)(c)(i))

Foreign Income

Capital Gains

Deductions, Releifs and Credits

Deduction

This change is critical for investment companies claiming a deduction for management expenses. The new field ‘managementExpensesUnder81D ‘ensures that any management expenses that are disallowable under the newly introduced Section 81D are separately identified and excluded from the total claim.

In our application within the Management Expense section under the ‘Deductions’ Tab in ‘Deductions, Reliefs and Credits’ page, a new field has been introduced for the same. The field under ‘Last Year’ column is read-only, where one can view the data in next year. The field under Current Year column is editable for the users.

•   If any amount entered at Management Expenses above refers to stock exchange listing expenditure under S81D, enter that amount here

Reliefs:

A newly introduced field ‘amtRelClaimedUnderSchedule24’ is applicable if your company is an Irish tax resident and has income that has been subject to tax in both Ireland and another jurisdiction. Schedule 24 provides the mechanics for claiming double taxation relief by allowing you to credit the foreign tax paid against your Irish corporation tax liability on that same income.

In our application under the ‘Reliefs’ Tab in ‘Deductions, Reliefs and Credits’ page, a new field has been introduced for the same. The field under ‘Last Year’ column is read-only, where one can view the data only in next year as a reflection of current years data. The field under Current Year column is editable for the users.

•   Amount of relief claimed in respect of dividend income under Schedule 24

Relief on Sports Donation Scheme:

Scheme introduces a streamlined process to claim tax relief on donations made to certain approved sports bodies, applicable from Jan 1^st 2025.

This change is applicable to your company if you make a qualifying donation in a year to an approved sports body for the sole purpose of funding an approved project. The scheme allows your company to claim tax relief by treating the donation as a deductible expense

In Relief subsection of ‘Deductions, Reliefs and Credits page’ a new link has been introduced. On clicking this link, it will open a new page for providing the details of Donations, that includes amount, Date of donation, Name of the sport body and Project details etc.

Following are the important fields:

Self-Assessment

Research and Development Credit

In this new fields for Amount introduced for each Instalment section ‘under Section 766D’ of  ‘Research and Development Credit’ page. Following are the fields have been set.

For 1st Installment section

1. Amount
2. Amount

For 2nd Installment section

1. Amount
2. Amount

For 3rd Installment section

1. Amount
2. Amount

Trading Result