Has private investment in renewable energy been adequately addressed in Ireland’s TSG’s budget papers?

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Has private investment in renewable energy been adequately addressed in Ireland’s TSG’s budget papers?

Sponsored by

Sponsored_Firms_deloitte.png
solar-835894.jpg

David Neary of Deloitte Ireland provides an overview of Ireland’s Tax Strategy Group’s (TSG) recommendations with respect to incentivising renewable energy.

The TSG Budget 2023 papers were published on August 10 2022. The TSG is a government think tank chaired by the Department of Finance and the published papers cover everything from income tax to EU developments to climate change.

Various groups, including Deloitte, have called for several tax measures to promote private investment in renewable energy – be it through funding or technological advancements.

Whilst the TSG Budget papers on ‘Climate Action and Tax’ reflect the operation of various excise duties, carbon tax measures and fuel related provisions there has been little in the way of recommendations to government when it comes to the stimulation many people are calling for to aid Ireland in meeting its 2030 climate goals, and indeed reduce Ireland’s reliance on foreign gas and oil to meet Ireland’s energy demands.

What can Budget 2023 contain to address this?

Corporate tax relief

Irish legislation previously provided corporate tax relief for equity investment in companies involved in renewable energy generation. This relief was introduced in Finance Act 1998 but was withdrawn in 2014. The relief was given in the form of a deduction from a company’s profits for its direct investment in new ordinary shares in a qualifying renewable energy company.

Coupled with the participation exemption regime Ireland operates on the sale of qualifying shares, such an additional relief will provide real-time benefits for companies who help fledgling renewable energy companies who are crying out for investment to realise their pipeline of renewable energy projects.

Promoting investment

Speaking of the participation exemption regime, Ireland is not in line with the UK when it comes to promoting investment in renewable energy companies, and this must be changed.

The sale of shares in a project company hosting an early-stage renewable project may not be in a position to claim the participation exemption as in Irish Revenue’s view the company may not be considered trading (broadly, that the project company should be trading is one of the conditions required for the participation exemption to apply). Revenue practice is to view trading as commencing when the project company commences producing electricity.

The participation exemption should be extended to the sale of companies that host early-stage development projects, i.e. that trading activities include activities for the purposes of a trade that a company is preparing to carry on. This will allow Ireland to be competitive when it comes to a jurisdiction for investors to deploy their capital when considering their green investment agendas.

Innovation hub

As Ireland expands its onshore wind, offshore wind (both fixed and floating), solar and biofuel industries, there is likely to be significant investment in research, development and innovation. With the proper incentives, Ireland could become an innovation hub for renewable energy. The R&D regime should be reviewed to ensure that it is first in class.

Incentivisation

Spending on green low consumption technology and buildings with recognised accreditation should be incentivised by way of super deductions or accelerated capital allowances.

The TSG Budget papers are simply a list of options and issues to be considered in the budgetary process and not binding on government decisions, however, it is disappointing that the incentivisation of private investment in renewable energy businesses and technologies are not to the forefront of the group’s recommendations to government.

If Ireland is to meet its climate goals, and also tap in to its expertise in technological advancement, it is important that the government take steps to kick-start investment.

more across site & shared bottom lb ros

More from across our site

Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour
Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions
The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition
From Instagram content to £100m transactions, the founder of Thomas & Co International discusses building a modern tax and accounting firm for business founders
Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures
Pillar two has been clients’ ‘biggest headache’ but also a driver of growth for MHA, which believes it has the edge over its big four rivals
Public country-by-country reporting is exposing multinational tax data to investors, journalists and competitors, creating fresh risks for businesses
Pillar two compliance is creating unprecedented data demands for multinational tax departments, making closer collaboration with FP&A teams essential for accurate reporting and audit readiness
Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute
ITR's podcast examines whether the big four have overarching cultural issues and assesses the competitive threat of technology-backed transfer pricing firms
Gift this article