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On-demand webcast
Watch as our panel of tax leaders provide in-depth analysis of the measures outlined by the Government in Budget 2024 and debate what this Budget means for Ireland, individuals, and organisations.
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Michael Rooney, EY Ireland Tax Partner
Tax Reliefs
“On Budget Day it’s all about the numbers and the magic number for taxpayers on Budget Day 2024 is €2,000. For a taxpayer earning €50,000 there is tax relief of €800, the energy tax credit will be €450 giving a total saving of €1,250 and finally for those who are renting the tax credit is €750 giving a total saving of €2,000.”
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Shane MacSweeney, Partner and Head of Government & Infrastructure, EY Ireland
Infrastructure, Climate and Nature Fund “Today’s announcement of the Infrastructure, Climate and Nature Fund is significant. Not only does it reaffirm the Government’s continued commitment to infrastructure investment in Ireland, it future-proofs it. All too frequently, infrastructure expenditure is one of the first areas to be cut during an economic downturn, so pre-empting this cycle via the establishment of a new Fund now is welcome long term, strategic decision making. Infrastructure investment is unique, in that not only does it boost productivity and economic growth, while also helping us to deliver on our Climate Action Plan, it also makes citizens lives better. With this certainty now in place, the focus now needs to be on delivery and turning our ambitious policy into physical delivery, which will only happen through collaboration and innovation.” -
Ian Collins, Partner and Head of Innovation Incentives, EY Ireland
R&D Tax Credit
“The decision to increase the R&D tax credit from 25% to 30% in today’s Budget is very welcome and will preserve and boost the attractiveness of Ireland as a global hub for R&D in a competitive international environment. The increase will be viewed very positively right across business, from the SME sector who can now avail of an additional benefit for performing R&D, through to the multinational sector where it will help to keep pace with forthcoming changes in the international tax environment for large corporations. Additionally, the doubling of the payment threshold to €50,000 to provide valuable cash-flow support to companies engaged in smaller R&D projects is very welcome and, together with the extension of the R&D tax credit is something that EY has advocated for.”
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Dr. Loretta O'Sullivan, EY Ireland Chief Economist and Partner
Budget 2024: Govt Seeks A Goldilocks Approach
“The Government has taken a Goldilocks approach to Budget 2024 seeking to get things ‘just right’ by striking a balance between giveaway and prudence and between the present and the future, all with the three bears – households, businesses, and economists – looking over its shoulder.
Getting it ‘just right’ is tricky in the context of an economy that is expected to grow but more moderately, inflation that is easing but a cost-of-living squeeze that is still being felt, an interest rate cycle that is nearing a peak but with past hikes increasingly impacting, strong employment but labour and infrastructure constraints, along with age and climate-related headwinds.
Increased welfare payments, cuts to personal taxation, further energy credits and business supports will be welcomed by many households and firms.
Spending on infrastructure and measures to spur innovation and boost the productive capacity of the economy, like the R&D tax credit adjustments, will be helpful in alleviating supply bottlenecks over the medium term. Moreover, the steps taken to increase the resilience of the public finances and the economy over the longer term are welcome, notably the Infrastructure, Climate and Nature Fund and the Future Ireland Fund.
In summary the Government has sought to strike a balance between spending and saving. Time will tell if they’ve gotten the balance ‘just right’”.
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Annette Hughes, Director, Economic Advisory, EY Ireland
Vacant Homes Tax
“The increase in the vacant homes tax is an important measure in the context of the challenges around housing supply and climate change. The fivefold increase in the local property tax charge should encourage owners to return their properties to use. However it’s important to caution that only a portion of these dwellings will be eligible, after exempt properties are excluded.
EY analysis of the vacant stock suggests the long-term vacancy figure is around 78,000 dwellings. Assuming the tax results in one-third of units released to the market (25,740), these units have the potential to accommodate around 71,000 persons based on an average household size of 2.74.
This measure should increase the supply for potential homeowners, and combined with the €50,000 grant for refurbishing a vacant home, should generate a win-win for local economic activity in areas where those properties are located.
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Alison McHugh, Tax Partner, Head of Private Client Services
Support for Businesses and Investors
“Today’s budget is one that is backing startups, SMEs and businesses and is to be applauded. The new relief for Angel Investors enabling a reduced rate of CGT on gains up to twice the value of the investment made by the investor, is really welcome. We expect this should further encourage investment in start-ups and growing businesses, who can often find it difficult to access traditional methods of finance in the earlier years.
The increase in the upper age limit from 65 to 70 on the CGT retirement relief will allow business owners greater flexibility in terms of the timing of the transfer of the business to their children to ensure that this is done at the right time. However, the introduction of a cap of 10m on the transfer of businesses up to the age of 70 from January 2025 may exclude a lot of business owners from being able to avail of this relief
Lastly, changes to the Key Employee Engagement Programme (KEEP) including extending the relief to 2025 and increasing the limit from 3million to 6million will go some way to help SMEs to reward and retain key employees, in particular those with the specialist skills needed to power our economy into the future.”
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Aidan Meagher, EY Ireland Tax Partner and Head of Life Sciences
The challenge for the current government for Budget 2024 lay in striking the balance between continuing to support households and business in the immediate term given the increased cost of living, while meeting its climate commitments and continuing to invest in capacity constraining areas like infrastructure, housing, and energy in order to support the economy and living standards into the future. To address the immediate term increased cost of living, the housing crisis and the cost of doing business, Minister McGrath introduced a series of tax measures. For individuals, these included expanding tax bands and credits, increasing the availability of rent credits, reducing the universal social charge and introducing a new mortgage interest tax relief. In addition the Budget seeks to promote the continued growth of SMEs with the introduction of entrepreneur relief for angel investors for innovative start-ups, enhancement of the existing EII investment scheme, increasing the age limit on CGT retirement relief and increase in the R&D tax credit to 30%.
The increase in the R&D tax credit from 25% to 30% is a positive step in reducing the impact of a Qualified Domestic Minimum Top-up Tax which brings the corporation tax rate to 15% for certain multinational enterprises. This will help in retaining Ireland’s competitiveness to secure future investment. We welcome the government’s forward-thinking approach allocating excess “windfall” corporation tax receipts to fund future challenges associated with an aging population, Ireland’s sustainability commitments and future infrastructure requirements.
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Roger Wallace, EY Ireland head of Assurance and EY Entrepreneur of the Year Lead Partner
Budget supports for Entrepreneurs
“Minister McGrath’s announcement of wide-ranging measures to support Irish innovation is to be welcomed. Entrepreneurs and indigenous companies are commonly competing in global markets in terms of funding, talent and of course in respect of their products and services. The increase in the R&D tax credit rate, first year payment threshold for smaller R&D projects, lower CGT rate for angel investors and enhancement of the existing EII investment scheme are all important drivers of high value activities and funding. This coupled with the cost of doing business package and efforts to simplify business taxes to ensure that all business know what reliefs they are entitled to demonstrates that the Minister is listening to those people who are creating in our economy and while it is never possible to meet all of the budget day demands, real progress has been communicated today.”
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Rachel Dillon, Head of Mobility, EY Ireland
Public Consultation on Share Based Remuneration
“Foreign Direct Investment and indigenous high-potential start-ups are crucial to the Irish economy and with the rise of share-based remuneration for employees in these areas, we welcome the announcement of an inclusive and transparent Public Consultation in this area. This is particularly important due to the onerous requirements that currently apply to employees who are awarded share options, and the recent increase in targeted Revenue interventions in this area. We are hopeful that these issues will be addressed during this consultation.”
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Rob Henson, EY Ireland Tax Partner
Irish companies and businesses have become very attractive as targets in M&A activity or for investment by Private Equity firms. Whilst there has been a softening in valuations being paid generally, many Irish entrepreneurs have benefited/continue to benefit from significantly higher multiples being paid when compared to a decade ago.
With this success, we have seen entrepreneurship growing at pace in Ireland, particularly, post Covid. As every business owner will testify, SMEs face an array of challenges including but not limited to the need to raise the necessary capital in order to accelerate their growth aspirations. The introduction of a reduced Capital Gains Tax (“CGT”) for angel investors should help incentivise investors to make investments in innovative SMEs and is therefore very welcome.
Full details of the relief will be included in the upcoming Finance Bill but, at a high level, the relief will allow for an individual investor to avail of reduced CGT rate of 16% (18% for investments via a partnership) on a gain up to twice their initial investment. The overall gain qualifying for this relief is capped at a lifetime limit of €3M so investments of up to €3M can qualify for this relief. The investor must hold their investment for a minimum of 3 years and the investment must be in fully paid up newly issued share capital representing between 5% to 49% of the ordinary share capital of the investee company.
There will be a certification process which will be carried out by Enterprise Ireland to ensure the relief is targeted at innovative SMEs and in compliance with the EU General Block Exemption.
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Cian O’Donovan, EY Ireland Tax Partner and Real Estate Tax Leader
Budget 2024 has made a number of notable changes for renters, homeowners, landlords and developers.
The increase in the rental tax credit from €500 to €750, whilst widely flagged, will be welcomed by renters and it is noteworthy that the relief will now also be available to parents who pay rent on behalf of student children in Rent a Room, or ‘digs’ accommodation.
Targeted relief for increased interest costs for tracker and variable rate mortgage holders for 2023 (versus 2022) will be welcomed by eligible mortgage holders.
Smaller landlords will now be able to access some relief at the standard rate for rent from residential property for the first €3,000 of income in 2024, €4,000 in 2025 and €5,000 in each of 2026 and 2027, but subject to a clawback if any of the properties held in Year 1, when the benefit is first claimed. This is not an immaterial relief and it will be interesting to observe its impact in helping to keep smaller landlords in the market.
Finally for developers, the deferral of the first payment date for Residential Zoned Land Tax from 1 February 2024 for one year is a sensible extension aimed at allowing further time for engagement with local authorities around potentially impacted sites.”
Budget 2024 Tax Alert
The challenge for the current government for Budget 2024 lay in striking the balance between continuing to support households and business in the immediate term given the increased cost of living, while meeting its climate commitments and continuing to invest in areas like infrastructure, housing, and energy.
Podcast: The Budget Briefing 2023 – 7 October
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Show transcript#Hide transcript
Jim Power: Hello and welcome to the Budget Briefing in association with EY. I'm Jim Power, and in this two part series, we're going to guide you through Budget 2024 and discuss the most significant and salient talking points for our Budget 2024 Preview. I'm delighted to be joined by EY Ireland Tax Partners Kevin McLoughlin and Michael Rooney. As we lumber up for the big, for the launch of Budget 2024, I guess there are strong economic and political imperatives at play here. The economy, while doing well, we've seen significant warnings from, for example, the SRB in recent days about the threats to the export performance, about the global headwinds that are blowing, and also about the domestic pressure on the consumer sector in particular. And we've had warnings from bodies such as the Central Bank of Ireland and the Irish Fiscal Advisory Council about the dangers of implementing a stimulatory budget in an environment where the economy is operating pretty close to full capacity. So that there's a lot of economic uncertainty out there despite the positive picture. But then we have the political element of it, and I think no budget can be seen in isolation from the politics. This is probably the second last budget before the general election, which is due by February 2025. Given the nature of coalition governments, it could well be the last, but it's certainly a budget that would be presented in the run up to an election. So obviously that is going to have a significant impact. Kevin, if I may start with you. You know, in broad terms, what do you think we can expect from budget 2024 next week? Kevin McLoughlin: Yeah, I think the expectation, Jim, is is probably well, firstly, probably expectation would be that we would probably hear a lot of the measures in the days before the actual budget is released on Tuesday. That certainly be kind of that the pattern of the last number of years. So I don't think the expectation here is of, you know, very, very surprising moves. And as you say, it's a very interesting dilemma that the government has because as you say, we're in full employment. We're running fairly significant surpluses. At the same time, there is a need to invest more and more into infrastructure, into housing, and you've got an inflationary environment which the government would say is still exceptional there for a while, taking the advice of the Fiscal Advisory Council that they should stick to their limits. They would say, well, the limits were probably set at a time of relatively low inflation and therefore that justifies going a little bit beyond that. I think at its core, and there's a couple of things that are being considered, and I think it's already out there that in terms of the total so-called budget package, the expectation is that probably 6 billion of the total package of around 7 billion would be in the form of spending, and that would be a mix of of some permanent spending measures and probably some further targeted temporary measures about the tax element of that will be in the order of just over 1 billion, €1 billion probably primarily. And Michael can comment on the specifics, this probably primarily in the areas of individual taxation rather than necessarily kind of business taxation. And it worth bearing in mind we still run significant levels of public debt or up over 220 to 220 billion. I was going to say. And obviously the other kind of big environmental factor around this, you know, particularly over the last couple of days and was was called out by the yes or I report is the the the the continuing let's just say dependence on the the huge growth in corporation tax revenues as a proportion of the overall government finances and the extent to which they are largely responsible in a way for the surpluses that are being generated in the last couple of years and are expected to continue to be generated in the years ahead. And there are certainly questions, particularly after the releases of the the August and September Exchequer finance figures as to the corporation tax takes for both of those months actually fell a little bit short of a target. And does that send any kind of longer term signal that actually perhaps these receipts are a little bit more volatile than people might have considered? Is there anything that the government should be concerned about in terms of longer term forecasting along those lines?
Jim Power: Yeah. Kevin, from ask you, in relation to the corporation tax piece we saw from the Exchequer returns at the end of September that in the three month period, July to September, the corporation tax take was 23% down on a year earlier and I know a year earlier was exceptionally strong. But what do you think is happening there and does it concern you in terms of how this might look into the future?
Kevin McLoughlin: I think the critical moment, Jim, is going to be November. It's probably the biggest month of the year in terms of. Corporation tax payments. And that can really will be the litmus test, I think, in terms of whether actually that trend is something we should be concerned about, are actually whether they are at year on year anomalies. I think certainly when the August numbers came out, it seemed to be able to attribute that to two very specific, you know, facts and circumstances in the prior year. And early indications are that something similar would have happened September last year. But I think all eyes will be on November as the biggest month of the year, just to see actually whether there is anything to concern about. Our sense is actually that the probably isn't you know, from an underlying perspective, I think the expectation that we would have is actually that these receipts will continue, will actually to continue to grow, perhaps not necessarily at the same rates of growth that they have been in recent years, but that they will continue to grow nonetheless.
Jim Power: Thank you, Michael. If I may ask you. You know, Kevin outlined there that the budget package is going to be basically around 6 billion in core and one spending and just over 1 billion in tax measures. Do you think that balance is correct between expenditure and taxation?
Michael Rooney: Yeah, it's really interesting. I think, you know, what they're really aiming for here is to put more money into as many people's pockets as possible. And if you look at it, I think it's trying to get the balance right and trying to have really kind of some targeted measures. If you look at it, you know, it's not a lot in terms of kind of like trying to spread it amongst about 3 million people. So, you know, I think really what we're looking at here is, is as Kevin has alluded to here, I think is where we probably will see this is U.S. cuts is is what they would really focus on. And if you look at the kind of you that, as Kevin said earlier, it's been with us since about 2011, I think it's obviously it's here to stay. You know, it gets it generates about 5 billion for the Exchequer per year. So it's a really significant amount of of of tax take that comes in. If we look at where they're going to target this, there are a number of different rates of U.S. If you look at bringing down, say, the four and a half percent rate to three and a half percent, the cost of that would be about 550 million. So it is a kind of significant part of what that budget will be. If you think about bring it down, really the kind of the the 0.5% rise to 0% that costs about 158 million. So I think, you know, they will really look at USC because it really kind of hits a large proportion of the population. What they will really focus on there, and I think after that will be really kind of increasing the standard rate band. So last year there was a significant increase that went up from 36800 to 40000. So that was really kind of significant in terms of of reducing the amount of tax that the people would have to pay. I could see that increasing again this year, probably going up to about by about 1500. The cost of that would be nearly 400 million as well. So those would be, I think, the kind of the two significant parts that that will play in terms of what that kind of like tax cuts will be and maybe, I think as well increasing the kind of pay the tax credit, if that went up by about, say, €50, that would cost about 127 million. So you can see they're between a little bit in terms of the decrease in USC, a little bit in terms of the standard rate band increasing and maybe a little bit of the piece of credit you have here. 1 billion there already that's that's used up in terms of tax relief. I I'm sorry, Jim, just in terms of the kind of the the the welfare side of this and this is, I think, the most significant part of it. You remember last year, the energy credits was a significant part of this. There was three different tranches of energy. Energy credits, €600 in total that was given out. I probably foresee that this will they will continue as well this year, but probably at a reduced rate. So maybe three tranches of €100 or maybe two of 150 that will come through. We also have the renter's tax credit that was provided for last year. That may increase as well. That's currently at €500 in terms of maximum relief for a single person. That may increase to 800 as well. So I think they will be targets again like they were last year. There will be significant increases as well in terms of your your usual welfare payments. So for for pensioners, for people with disability, we are thinking they would probably go up by 10 to €12 as well. So there's a number of packages there that will be targeted at different parts of the population.
Jim Power: Michael, In relation to the U.S., and this is probably not a very popular view, but I tell it from one of the virtues of the U.S. when it was introduced was that it addressed a serious problem in the Irish tax system, which was the narrow base from which we collect the tax. So I always ideologically believe that's. Tax base with headline rates as low as possible, was the most economically advantageous position in recent budgets. We've seen, you know, a gradual reversal of that. U.S. rates have been coming down. The number of people paying us has been declining. And do you do you think that's a retrograde step in terms of tax reform from a longer term perspective?
Michael Rooney: Yeah, there is a lot of discussion about this, and I think it is obviously it's quite politically sensitive as well. We've heard especially even cynical, saying they want to they want to remove U.S. in the future. It was brought in and we did think it was going to be a temporary measure. But as I've said, you know, it's so important to the economy now as well that it does bring in in more than kind of like 5 billion. I do see that. You know, as I said, it is very progressive in nature. So you obviously pay more depending on your earnings. However, I think, you know, it's it is it does complicate the fact that we have income tax. We have U.S. as well. You know, there are lots of talks about reform happening. In the last budget, they announced that we're going to look at Russian reform in more detail. I do think we haven't seen that yet, but I think it it'll really probably happen in the next kind of 12 to 18 months that it will look to reform it.
Jim Power: Okay. And Kevin, if I may bring you in there in relation to the business sector and I guess particularly SMEs, but not necessarily just the business sector generally. I'm going to put this question in two tranches, if I may. What would you like to see happening? What do you think should happen? What do you think is likely to happen?
Kevin McLoughlin: Yeah, I think, you know, the budget generally, you know, the profile tends to be very much focussed on individuals and there tends to be then some quite specific measures directed to business. I think the biggest issues that businesses are looking for, for I would say assurance are reassurance on will be around the fact of cost pressures. So we still have higher than historic levels of inflation. We still we are, as you said earlier, we're at full employment. So there's still a fair degree of wage inflation. Some of that obviously exacerbated in the last year or two by by add by inflation more generally. And I think you've got huge pressures on infrastructure, housing cost, competitors of businesses and large Irish businesses are generally actually quite export led to that need to be competitive in trading in the international markets in which they operate, I think is really important. And so I actually think those are issues that I think business will be looking very closely at in terms of where spending measures are directed and not just kind of the one off short term. And some of those from an energy perspective were helpful in the last year or so. They're probably much more interested in the investments in infrastructure that will be necessary in order to keep Ireland competitive, because I think a lot of the focus, for example, on the the levels of corporation tax returns is very much of corporation tax take. And actually underlying all of that is probably a risk of a dependence on a relatively small number of of FDI businesses in Ireland. There there, you know, willingness to stay here is fundamentally dependent on the competitiveness of Ireland as a location to bid to do business taxes, becoming a I will say it's a lesser issue. It's important. The international tax landscape is changing quite dramatically. I'll come back to that in the second. But competitiveness more broadly actually, I think is probably the biggest issue that business is looking for comfort. And there are specific calls, again, I think from an innovation perspective to look to increase the amount of the research and development tax credits currently sits to slightly higher number. That's actually quite an effective credit as things stand with Turkey in order to keep them competitive internationally. There have been calls to to to to up the rate of relief there. I probably do. The thing I would say is that kind of almost in the background, you have a really significant set of changes that are going to land in Ireland probably in the next week or two through the finance bill, which is going to deal with these fundamental changes that are happening from a broader international tax policy perspective so that the increase to an effective rate of 15% from 12 and a half percent, this whole BEPS Pillar two agenda, which again is Ireland, is very much in the middle of as is the rest of the world. So so I think at a certain level, businesses generally are looking very much at measures that enhance Ireland's competitiveness. I think at the bigger end, multinational businesses, both Irish and and and and FDI very much have an eye to how Ireland is going to implement these new measures. And one of the things that I think has been a huge positive for Ireland over the years is stability. Ireland signalled early that it will go with this kind of global minimum tax rate strategy, I think as part of the stabilising message. But I think it will be really important in terms of how these measures are implemented in the weeks and months ahead that it's all very clear that it's all aligned with what how businesses have been told these measures will be implemented in order to maintain that stability going forward, because as I say, that's been a huge advantage for us relative to, say, instability or volatility and fiscal policy in the UK and even in the US, where with significant elections next year, again, there's there's very significant questions as to the direction of travel there as well.
Jim Power: Yeah, Kevin, I've just you mentioned comparisons a few times there and clearly global tax developments are going to remove some of Ireland's relative competitive position vis a vis taxation. So what do you think are the other other elements of competitiveness that are essential for continued strong foreign direct investment into the economy? Because at the end of the day, train of 1000 people employed by IDA supported companies at the end of last year, 57% of corporation tax coming from ten companies. So FDI is a very important part. Where do you think the focus needs to be in terms of other elements of competitiveness?
Kevin McLoughlin: Yes. So I think on the tax side, at least, you know, if there is a convergence towards an agreed minimum rate that does. Take some of the relative competition out of this, albeit there are other jurisdictions that are outside of that framework that still would look to be very, very competitive on tax. I think when you take tax out of the equation, it is you know, it is labour cost and I could speak very knowledge of the about the importance of the ability of Ireland to continue to be able to attract talent into Ireland as a way of, of bringing top talent to support existing operations and to attract new operations. And that gets us into politically sensitive areas like the SERP, which is the Strategic Signing Relief program, which Michael is more expert than I am in. But but I think cost of labour is critical, especially in a full employment economy like Ireland's. Therefore, that need to continue to tap into into overseas talent to help kind of staff staff employment that we have. I think housing and I think broader infrastructure and transport I think is actually what business is far more interested in now than necessarily particular particularly specific tax issues.
Michael Rooney: I think sorry, Jim, just to add on that, I think I think it is important to be competitive from an individual income tax perspective as well. We look at it here and as Kevin has pointed out, sorry, does really kind of equalise it a lot more. We have a really high rate of tax. If you look at 52%, you compare that to the U.S. and you're talking about a kind of like a highest federal tax rate of 37%. So having staff there really does kind of like really kind of equalise it a lot in terms of kind of like attracting talent in here as well. So I think that's that's obviously going to be in place till 2025. You know, companies like to have certainty. They like to see kind of like what is the long term outlook. So, you know, maybe having that kind of like around for a little bit longer may just help in terms of that competitiveness that we need to have.
Jim Power: Okay. And Michael, finally, can I just ask you about housing specific measures? You mentioned an increase in the renters tax relief. Anything else possible?
Michael Rooney: Yeah, I think renters tax credit is one that that we see that may happen, obviously, just because it is already in place and there may be an increase in it. There has been some talk about mortgage interest relief. Obviously, I think if that was to come in place, would need to be very, very targeted. You know, if you could see that was that was open to kind of anybody with a qualifying loan who wants it to look at their having a new swimming pool or tennis court as well. Back in 2004. But we need to look at, you know, targeted measures that are really going to help people who are really facing the pressures brought on by, you know, kind of high interest rates. So I think mortgage interest rates is definitely one that that that tax relief that we could see happening as well. I think that would be really welcome for people are really struggling with with the high cost of mortgages at the moment.
Jim Power: Okay. We're up against the clock, so I will wrap it there. Folks, thank you very much for participating in the budget briefing in association with e! Y. That's all for episode one. Make sure you join us next Wednesday for our review podcast, where we will look and analyse the key elements of Budget 2024 and talk about what's included as and I guess more importantly, what's not included and what we'd like to see in the future. So thank you very much and I look forward to talking to you again next Wednesday when we can talk with greater knowledge about Budget 2024.
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Summary
If you would like to learn how Budget 2024 will impact you and your business, please continue to check back on this page. The page will be continually updated with real-time insights, analysis and commentary on 10 October 2023.
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