Budget 2025 and Stamp Duty on Residential Property

10% rate for bulk purchases increased to 15%: The former 10% rate that had been applied to purchases of 10 or more residential properties in any one year, except for apartments in an apartment block (which is a multi-storey property comprising 3 or more apartments with common or grouped access) and residential properties acquired by home reversion firms, has been increased to 15%.  There is no change to how it has been applied otherwise, except to provide that the rate shall not apply to the transfer of shares in the National Asset Residential Property Services DAC, on or before 31 December 2025, by NAMA or any NAMA group entity to the Land Development Agency.

New 6% residential rate: The Finance Bill provides a further change in law (when enacted) to the financial resolution enacted on Budget night with respect to the new 6% stamp duty rate. This is to ensure that a conveyance or transfer on sale of 3 or more apartments in an apartment block will continue to be subject to stamp duty at a rate of 1% on the first €1,000,000 and 2% thereafter (with the new 6% rate not applying to those apartment sales).

This means that except on (i) bulk purchases subject to the 15% rate and (ii) purchases of 3 or more apartments in an apartment block, where 1% will apply to the first €1,000,000 and 2% thereafter, for all other purchases of residential property the following rates will apply:

• 1% on the first €1,000,000;
• 2% on the next €500,000; and
• 6% on any balance consideration or value.

Purchasers should be aware that while purchases of 3 or more apartments in an apartment block are excluded from the 6% rate, where one such apartment is bought, or two such apartments are bought as part of the same transaction or series of transactions, the 6% rate will apply to any combined value in excess of €1,500,000.

Transitional measures for new rates

The new 6% and 15% rates apply to all instruments attracting the relevant rate executed on or after 2 October 2024 unless the instrument satisfies the following transitional criteria:

• it is executed on or before 31 December 2024;
• pursuant to a contract that was entered into on or before 1 October 2024; and
• the instrument contains a certificate to that effect in a form specified by Revenue.

4 year timeframe for claiming repayment of stamp duty paid on contracts or licences for transactions that do not complete

The Finance Bill also requires future claims for repayment of stamp duty paid on contracts or licences for the sale or development of property (as resting in contract arrangements) which do not ultimately complete, to be made within 4 years of the original stamp duty filing.