Electronic Share Trading (CREST)
Market capitalisation exemption
Finance Bill 2025 provides for the introduction of a new Stamp Duty exemption for acquisitions of stocks and marketable securities (relevant securities). The proposed exemption will come into operation on 1 January 2026 and apply until 31 December 2030.
Qualifying Conditions
The proposed exemption will apply if these three conditions are met.
Condition One
At the date of the transaction, the relevant securities are admitted to trading to a relevant market.
A relevant market is:
- A regulated market within the meaning of the MiFID II Directive. (For example, Euronext Dublin)
- A multilateral trading facility within the meaning of the MiFID II Directive. (For example, the Euronext Growth market operated by Euronext Dublin)
- or
- A market outside the European Union which is equivalent to a regulated market or multilateral trading facility. (For example, the London Stock Exchange)
Condition Two
The closing market capitalisation of the issuer of the relevant securities was below €1 billion on 1 December of the previous year.
If the relevant securities were admitted to trading after 1 December of the previous year, an alternative condition applies. This alternative condition is that the expected market capitalisation of the issuer upon admission to trading was below €1 billion.
Condition Three
The transaction takes place during the exemption period.
Exemption Period
The exemption cannot apply unless a valid notification to Revenue of the applicable market capitalisation is made.
Where a valid notification of an issuer's closing market capitalisation at 1 December of a particular year is made, the exemption period:
- commences 2 weeks after the notification is made or 1 January of the following year, whichever is the later
- and
- ends on the following 31 December.
- Example 1
A valid notification in respect of the market capitalisation of a company on 1 December 2025 is made on 6 December 2025. The exemption period:
• commences 1 January 2026
and
• ends 31 December 2026.
- Example 2
A valid notification in respect of the closing market capitalisation of a company on 1 December 2025 is made on 2 January 2026. The exemption period:
• commences on 16 January 2026
and
• ends on 31 December 2026.
Where a valid notification of an issuer’s expected market capitalisation upon admission to trading after 1 December of a particular year is made, the exemption period:
- commences 2 weeks after the notification is made, or 1 January of the following year, whichever is the later
- and
- ends on the following 31 December.
- Example 3
A company is to admit relevant securities to trading to a relevant market on 27 February 2026. A valid notification in respect of the expected market capitalisation of the company is made on 12 February 2026. The exemption period:
• commences on 27 February 2026
and
• ends on 31 December 2026.
How to Make a Valid Notification
A valid notification in respect of the applicable market capitalisation can be made to Revenue by:
- the market operator
- or
- the issuer of the relevant securities.
You must email CREST@revenue.ie to make a valid notification for the following:
Relevant information in support of the notification is to be included. This should include an explanation as to how the market capitalisation was calculated.
Help
If you require any assistance, email CREST@revenue.ie. When emailing please use the Subject “Market cap exemption”.
Details of the information notified to Revenue will be published on this page.
How to Claim the Exemption
The exemption can be claimed:
- where relevant securities traded electronically - in the electronic settlement system
- or
- where relevant securities transferred by stock transfer form - in a Stamp Duty return filed via the e-Stamping system.