FUTURE IRELAND FUND AND INFRASTRUCTURE, CLIMATE AND NATURE FUND ACT 2024

SCHEDULE 1 Amendments of Acts

SCHEDULE 1

Amendments of Acts

Section 37(1)

PART 1 Amendment of Taxes Consolidation act 1997

PART 1

Amendment of Taxes Consolidation act 1997

Item (1)

Item

(1)

Provision affected (2)

Provision affected

(2)

Amendment (3)

Amendment

(3)

1

1

Section 172A(1)(a)

Section 172A(1)(a)

In subparagraph (i) of the definition of “relevant distribution”, insert the following clause after clause (IB): “(IC) a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner,”.

In subparagraph (i) of the definition of “relevant distribution”, insert the following clause after clause (IB)

“(IC) a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner,”.

2

2

Section 230

Section 230

Insert the following subsection after subsection (1A): “(1B) Notwithstanding any provision of the Corporation Tax Acts, profits arising to a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner shall be exempt from corporation tax.”.

Insert the following subsection after subsection (1A)

“(1B) Notwithstanding any provision of the Corporation Tax Acts, profits arising to a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner shall be exempt from corporation tax.”.

3

3

Section 246

Section 246

In subsection (3): (a) in paragraph (ec)— (i) in subparagraph (ii), delete “or”, (ii) in subparagraph (iii), insert “or” after “sole beneficial owner,”, and (iii) insert the following subparagraph after subparagraph (iii): “(iv) a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner,”; (b) substitute the following paragraph for paragraph (ed): “(ed) interest paid by— (i) a Fund investment vehicle (within the meaning of section 37 of the National Treasury Management Agency (Amendment) Act 2014), or (ii) a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024), of which the Minister for Finance is the sole beneficial owner,”.

In subsection (3)

(a) in paragraph (ec)—

(i) in subparagraph (ii), delete “or”,

(ii) in subparagraph (iii), insert “or” after “sole beneficial owner,”, and

(iii) insert the following subparagraph after subparagraph (iii)

“(iv) a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner,”;

(b) substitute the following paragraph for paragraph (ed)

“(ed) interest paid by—

(i) a Fund investment vehicle (within the meaning of section 37 of the National Treasury Management Agency (Amendment) Act 2014), or

(ii) a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024),

of which the Minister for Finance is the sole beneficial owner,”.

5

5

Section 256(1)

Section 256(1)

In paragraph (a) of the definition of “relevant deposit”, insert the following subparagraph after subparagraph (iia): “(iib) a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner,”.

In paragraph (a) of the definition of “relevant deposit”, insert the following subparagraph after subparagraph (iia)

“(iib) a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner,”.

6

6

Section 730D

Section 730D

In subsection (2): (a) in paragraph (ca), delete “or”; (b) in paragraph (cb), substitute “assurance company, or” for “assurance company.”; (c) insert the following paragraph after paragraph (cb): “(cc) where the life policy is an asset held by a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner, and the National Treasury Management Agency has made a declaration to that effect to the assurance company.”.

In subsection (2)

(a) in paragraph (ca), delete “or”;

(b) in paragraph (cb), substitute “assurance company, or” for “assurance company.”;

(c) insert the following paragraph after paragraph (cb)

“(cc) where the life policy is an asset held by a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner, and the National Treasury Management Agency has made a declaration to that effect to the assurance company.”.

7

7

Section 739D(6)

Section 739D(6)

Insert following paragraph after paragraph (kb): “(kba) is a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner, and the National Treasury Management Agency has made a declaration to that effect to the investment undertaking,”.

Insert following paragraph after paragraph (kb)

“(kba) is a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner, and the National Treasury Management Agency has made a declaration to that effect to the investment undertaking,”.

8

8

Schedule 15, Part 1

Schedule 15, Part 1

Insert the following paragraph after paragraph 33A: “33B. A relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner.”.

Insert the following paragraph after paragraph 33A

“33B. A relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner.”.

PART 2 Amendment of Stamp Duties Consolidation Act 1999

PART 2

Amendment of Stamp Duties Consolidation Act 1999

Item (1)

Item

(1)

Provision affected (2)

Provision affected

(2)

Amendment (3)

Amendment

(3)

1

1

New section

New section

Insert the following section after section 108C: “Future Ireland Fund and Infrastructure, Climate and Nature Fund 108D. Stamp duty shall not be chargeable under or by reference to any Heading in Schedule 1 on an instrument for the sale, transfer, lease or other disposition of any property, asset or documentation to a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner;”.

Insert the following section after section 108C

“Future Ireland Fund and Infrastructure, Climate and Nature Fund

108D. Stamp duty shall not be chargeable under or by reference to any Heading in Schedule 1 on an instrument for the sale, transfer, lease or other disposition of any property, asset or documentation to a relevant Fund investment vehicle (within the meaning of section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024) of which the Minister for Finance is the sole beneficial owner;”.

SCHEDULE 2 Amendment of Return of Payments (Insurance Undertakings) Regulations 2011 (S.I. No. 641 of 2011)

SCHEDULE 2

Amendment of Return of Payments (Insurance Undertakings) Regulations 2011 (S.I. No. 641 of 2011)

Section 37(2)

Item (1)

Item

(1)

Provision affected (2)

Provision affected

(2)

Amendment (3)

Amendment

(3)

1

1

Regulation 2

Regulation 2

Insert the following definition: “ ‘relevant Fund investment vehicle’ has the same meaning as it has in section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024;”.

Insert the following definition

“ ‘relevant Fund investment vehicle’ has the same meaning as it has in section 32 of the Future Ireland Fund and Infrastructure, Climate and Nature Fund Act 2024;”.

2

2

Schedule 2

Schedule 2

In paragraph 6, substitute the following paragraph for paragraph (e): “(e) the National Treasury Management Agency, a Fund investment vehicle, a relevant Fund investment vehicle, or the State acting through the National Treasury Management Agency, a Fund investment vehicle or a relevant Fund investment vehicle,”.

In paragraph 6, substitute the following paragraph for paragraph (e)

“(e) the National Treasury Management Agency, a Fund investment vehicle, a relevant Fund investment vehicle, or the State acting through the National Treasury Management Agency, a Fund investment vehicle or a relevant Fund investment vehicle,”.