Ireland Startup Tax Reliefs 2025 — Section 486C, EII, SURE & Angel Investor Relief

The original scaffold for this page named "SARP" as a start-up relief — that is a mix-up. SARP (Special Assignee Relief Programme) is unrelated: it relieves employees assigned into Ireland by a foreign employer, not start-up companies or their investors. The four reliefs that actually apply to Irish start-ups and the people who fund them are Section 486C, EII, SURE, and Angel Investor Relief.

Section 486C — relief for the company itself

A new trading company gets a reduction of its own Corporation Tax for the first five years of trading, covering CT on trading profits and on chargeable gains from the disposal of assets used in the trade. Full relief applies where the company's CT liability for the year is €40,000 or less; marginal (partial) relief applies between €40,000 and €60,000; above €60,000 there is no relief. The relief is also capped by the employer PRSI the company actually pays, so a company with very few employees gets less benefit than the CT thresholds alone would suggest.

EII — income tax relief for outside investors

The Employment Investment Incentive gives an individual investor income tax relief on amounts invested in a qualifying SME's new shares, up to €1,000,000 in a year (raised from €500,000 at Budget 2025/2026). The relief rate is tiered by the company's maturity and fundraising history — highest for a pre-revenue company raising its first round, lower for a company on a later or repeat raise — rather than a single flat percentage for every investment. Shares must generally be held for 4 years, or 7 years for the higher end of the investment limit, and the scheme is currently legislated for shares issued up to 31 December 2026.

SURE — a refund for founders, not new relief

Start-Up Relief for Entrepreneurs works differently: instead of relieving income you are about to earn, it refunds Income Tax you already paid in earlier years. An individual founder who invests in their own qualifying start-up can claim relief on up to €140,000 of that investment, set against PAYE income tax paid in the current or any of the previous six years — in effect turning past PAYE contributions into a cash refund that helps fund the new venture.

Angel Investor Relief — a reduced CGT rate, not an income tax relief

The newest of the four, Angel Investor Relief ("Relief for Investment in Innovative Enterprises") is a Capital Gains Tax relief, not an income tax one. A qualifying individual investor pays CGT at a reduced 16% (18% for a qualifying partnership) on the gain from disposing of eligible shares in a certified innovative SME, instead of the standard 33%. The reduced rate only applies to a gain of up to twice the value of the original investment, and is subject to a lifetime limit of €10 million — raised by Finance Act 2024 from the €3 million originally proposed in the Finance (No. 2) Act 2023. Shares must be held at least three years, the investment must be made by 31 December 2026, and the company must first obtain a certificate from Revenue (following consultation with Enterprise Ireland) confirming it is a genuine going concern engaged in commercial innovation. Because State Aid approval was required, the scheme only began operating on 1 March 2025, later than its original legislative date.

How the four fit together

A single funding round can touch more than one of these at once: the company claims Section 486C on its own early-year profits; an outside investor buying new shares claims EII on their income tax; the founder, if also putting personal money in, may claim SURE against tax already paid; and if that same outside investor later sells the shares at a gain, Angel Investor Relief (not EII) is what reduces the CGT on the exit — the reliefs sit at different points in the company's life and the investor's own tax position, rather than duplicating one another.

FAQ

Q: Can an investor claim both EII and Angel Investor Relief on the same shares? A: They apply to different events — EII relieves income tax when you invest, Angel Investor Relief reduces CGT when you later dispose of the shares at a gain — so the same shares can, in principle, touch both at different points, subject to each relief's own conditions being met.

Q: Does SURE apply to any startup investment, or only my own company? A: SURE is specifically for an individual investing in a qualifying company where they become a director or employee — it is aimed at founders funding their own venture, not passive outside investors, which is what separates it from EII.

Q: What's the practical difference between Section 486C and the investor-side reliefs? A: Section 486C reduces the company's own Corporation Tax bill; EII, SURE and Angel Investor Relief instead reduce the personal Income Tax or CGT of the people who put money into the company — one relief acts on the business, the other three act on the individuals funding or founding it.

Sources

Figures verified against Revenue guidance and Finance Act commentary as of 30 July 2026:

• Revenue — "Tax relief for new start-up companies" (Section 486C) (five-year window, €40,000/ €60,000 full/marginal relief thresholds, employer-PRSI cap on the relief)
• Revenue — "Employment Investment Incentive (EII)" (€1,000,000 annual investor limit, 4-year/ 7-year holding periods, relief legislated for shares issued up to 31 December 2026)
• Revenue — "Start-Up Relief for Entrepreneurs (SURE)" (€140,000 investment ceiling, refund against PAYE tax paid in the current or preceding six years)
• Finance (No. 2) Act 2023 and Finance Act 2024, as reported by multiple professional tax advisories (KPMG, PwC, Arthur Cox, Beauchamps) (Angel Investor Relief: 16%/18% CGT rate, gain capped at twice the investment, lifetime limit raised from €3 million to €10 million, 3-year holding period, scheme commenced 1 March 2025 following State Aid approval)