CGT Entrepreneur Relief in Ireland: Selling a Business, Revenue Guide

CGT entrepreneur relief in Ireland, now called revised entrepreneur relief, gives a reduced rate of capital gains tax (CGT) on the sale of qualifying business assets or shares by an individual. For owners planning to sell a business, the relief can matter a great deal, but it comes with conditions on ownership, the type of business and the time you personally spend in it. This guide sets out the conditions in outline, how the relief fits into the CGT return, and the points to check with Revenue's current pages. Company disposals are charged differently, which we cover in our guide to chargeable gains for companies.

Entrepreneur relief and revised entrepreneur relief

Revenue's page on revised entrepreneur relief (published 7 October 2026) explains that the relief replaced the original entrepreneur relief, which applied for 2014 and 2015. Revenue's Tax and Duty Manual Part 19-06-02B (last updated April 2026) says that section 597AA of the Taxes Consolidation Act 1997 provides the reduced rate on disposals of chargeable business assets by a relevant individual on or after 1 January 2016. It supersedes the earlier section 597A for disposals from that date, although the manual notes that section 597A still applies where it gives greater relief.

Two points follow. First, the relief is for individuals, not for a company selling its own assets. Second, it applies to chargeable business assets and to qualifying shares, not to everything an owner might sell.

The reduced rate and the lifetime limit

The figures below were shown on the Revenue web page and manual named above. They can change, so check Revenue's page on the day you plan a disposal.

• The relief gives a CGT rate of 10% on gains from the disposal of chargeable business assets. For disposals from 1 January to 31 December 2016, the rate was 20%.
• There is a lifetime limit on the gains that qualify. Revenue shows a limit of €1,000,000 for gains arising between 1 January 2016 and 31 December 2025, and €1,500,000 for gains arising on or after 1 January 2026.
• You add together all prior gains on qualifying disposals to see whether you have reached the limit. The manual says gains above the limit are taxed at the standard rate.

On the standard rate, Revenue's own pages differ. The web page on the relief says the relief reduces the rate from the standard 31%, and Revenue's page on how to calculate CGT says the rate for most gains changed to 31% on 7 October 2026. The manual, last updated April 2026, uses 33% in its examples. This guide asserts neither figure as the rate that applies to your disposal; confirm the current rate before you model the tax.

Conditions in outline

Revenue's web page and manual describe the conditions. In summary:

• Ownership period. For business assets, you must have owned them continuously for three years within the five years before disposal. For shares, you must have held at least 5% of the ordinary shares for three continuous years, and the manual says that period can fall at any time before the disposal. The manual adds that spouses' periods cannot be combined and that periods before and after incorporation cannot be combined.
• Qualifying business. The asset must be used in a qualifying business, which excludes holding investments, holding development land, and developing or letting land.
• Company shares. The shares must be ordinary shares in a trading company or in the holding company of a qualifying group. Revenue's page notes that dormant companies or non-trading subsidiaries can prevent qualification.
• Time devoted to the business. For shares, you must have been a director or employee and spent at least 50% of your working time in a managerial or technical role for three continuous years within the five years before disposal. Time in other companies of a qualifying group can count.

The manual says Revenue may ask for supporting evidence of working time, such as payroll or charging records. Our suggestion: keep a simple dated record of your role and time commitment in each year, well before any sale is on the horizon.

What does not qualify

Revenue's web page lists disposals that do not qualify:

• Shares, securities or other assets held as investments, unless they qualify under the relief.
• Development land.
• Assets on which no chargeable gain arises.
• Assets you own personally and a company uses, where the assets are outside the company.
• Goodwill sold to a connected company.
• Shares where you remain connected with the company after the disposal.

For the last two items, the manual says the relief may still apply if the disposal is for genuine commercial reasons and is not part of a tax avoidance arrangement. The manual also says relief can be restricted where a business is transferred to a company in exchange for something other than shares, again subject to the same commercial reasons exception.

Situations the manual specifically addresses

The manual discusses a number of situations where the relief can arise, including share buybacks within the CGT charge, liquidations where the company carried on a qualifying business until the liquidator was appointed, double holding company structures, and partnership assets used in a qualifying business. For liquidations it says the liquidation must be completed within a reasonable period and that Revenue regards two years as reasonable. Because these are fact-sensitive, read the manual and take advice rather than relying on this summary.

How the relief is claimed

Revenue's web page does not set out a separate application form. Under the heading on how to claim, it tells you to calculate your CGT using the reduced rate on gains from chargeable business assets. In practice that means the relief is reflected in the CGT return. Revenue's pages on the relief do not describe the exact fields to complete, so check Revenue's current return guidance and your agent's instructions.

Revenue's page on how to pay and file CGT (published 2 October 2026) says a return is due by 31 October of the year following the disposal, even if no tax is due. It gives payment dates of 15 December for disposals from 1 January to 30 November, and 31 January of the following year for December disposals. It says late payment attracts interest and late returns attract a penalty. You register for CGT on ROS or myAccount before paying. These dates are stated on the page at the time of writing, and you should confirm them before relying on them.

CGT has its own payment dates. If the sale also affects your wider tax position, see our guide to preliminary tax deadlines and payment rules, so that the two sets of obligations are planned together.

Practical steps before selling a business

A practical approach, offered as our suggestion and not as a legal requirement:

• Test each condition against your own history: ownership dates, shareholding percentage, qualifying business status and your role.
• Check how much of your lifetime limit earlier qualifying disposals have used.
• Review the company's activities for investment or property elements that could count against a qualifying business.
• Agree the sale structure with your tax adviser before signing, because the manual shows that structure affects the relief.
• Put your tax affairs in order. A buyer, lender or adviser may ask about your compliance position, and our guide to the tax clearance certificate explains the process.

What this guide does not cover

This guide does not cover clawback rules, how earlier gains are aggregated in detail, or the tax position of the buyer. It also does not cover reliefs or exemptions outside revised entrepreneur relief. It is general information, not tax advice.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Is entrepreneur relief the same as revised entrepreneur relief?

Revenue says revised entrepreneur relief replaced the original entrepreneur relief, which applied for 2014 and 2015. The current relief is in section 597AA TCA 1997.

Can a company claim the relief?

The manual describes it as a relief for a relevant individual disposing of chargeable business assets. A capital gain made by a company is usually included in the company's profits for corporation tax, as Revenue's page on capital gains for companies explains.

Do I need to own the whole company?

No. For shares, Revenue's page refers to holding at least 5% of the ordinary shares for three continuous years, together with the time you spent working in the business.

Do I file a return if the relief reduces my tax?

Revenue says a CGT return is due for any disposal, even if no tax is due, so yes.

Where do I check the current limit and rate?

On Revenue's revised entrepreneur relief page and the Tax and Duty Manual Part 19-06-02B. Figures change, so check on the day.

If you are considering a sale, get tax advice early, because the conditions are tested over several years before the disposal.