Ireland’s 2025 Form 11: the new CGT, PRSA and split-year disclosures

What changed in the 2025 Form 11

The 2025 Form 11 asks for materially more detail than its predecessor, and the changes cluster around exactly the positions that internationally mobile founders rely on. Revenue set them out in eBrief 127/26 on 31 August 2026, with the full list in Tax and Duty Manual Part 38-01-04J. The form itself has been available in the Revenue Online Service since 1 January 2026, and it is filed under the standard self-assessment pay and file deadline of 31 October 2026, extended into November for those who both pay and file through ROS.

Most of the amendments are routine housekeeping: updated tax-credit values, residential-relief mechanics, farmland-leasing fields, and similar. Three, however, change what a founder or a cross-border individual has to reveal, and they are the subject of this article: new capital gains tax fields for deferrals and reliefs, a new treatment of excess employer pension contributions, and a requirement to detail split-year treatment. None of the three is a new tax. Each is a new disclosure, and a disclosure is where a tax authority looks first.

The CGT panel now tracks your deferrals and reliefs

The capital gains tax panel is where the most consequential change sits, because it now records not just the gain but the history of any deferral. Paragraph 12.1 of the manual adds new fields to the CGT panel for claims to defer payment, claims to reliefs, and tax previously deferred that is now due. Paragraph 12.2 adds sections to the CGT self-assessment panel for tax deferred in the period, and for tax previously deferred and now falling due. The return, in other words, now carries the deferral forward and asks each year whether it has crystallised.

For a founder this is the reporting counterpart to the reliefs analysed elsewhere on this site. A claim to Revised Entrepreneur Relief, the 10% rate on qualifying business disposals, is a relief claim that now sits in a structured field rather than in a computation. More significantly, the deferral mechanics of Retirement Relief, where tax on a transfer to a child above the €10 million cap can be deferred and abated only if the child holds the business for twelve years, map directly onto the new "tax previously deferred and now due" field. Where that twelve-year condition fails and the deferred tax becomes payable, the form now has a specific place to declare it. A deferral that was once a note in a file is now a line Revenue can match against the year it was created.

Excess employer PRSA now surfaces as taxable income

The pension change closes a loop that opened when the contribution rules tightened, and it does so by forcing the excess onto the face of the return. Paragraphs 5.2 and 8.1 of the manual provide that where an employer's contribution to an employee's PRSA exceeds the maximum, the amount above the limit must be entered in the gross amount of taxable income field on the PAYE, BIK and pensions panel. The excess is no longer a matter of separate computation; it is declared as taxable income.

This follows directly from the reform covered in the employer PRSA contribution limit analysis. From 1 January 2025 a tax-relieved employer contribution to a PRSA is capped at 100% of the employee's emoluments, and anything above that is a taxable benefit. The 2025 Form 11 is the first return on which that cap is self-policing: an owner-director who ran a large employer contribution through the company now reports the excess as income on the same form, in a field designed to capture it. For anyone who used the pre-2025 window aggressively, the return is where the position becomes visible.

Split-year treatment must now be detailed

The residency change removes the ambiguity that used to surround an arrival or departure year. Paragraph 7.2 requires that where split-year treatment has been claimed against income in 2025, details must be included on the return. Split-year treatment, under section 822 TCA 1997, allows an individual arriving in or leaving Ireland part-way through a year to be treated as resident only from or up to the date of the move, so that employment income earned outside that period falls outside the Irish charge. It is the mechanism that makes a clean corridor move work.

Requiring the detail on the return matters because split-year treatment is precisely the point at which a UK, UAE or Irish move is most exposed. The claim depends on the facts of the move, and those facts have to align with the individual's position under the UK Statutory Residence Test on the other side of the corridor. Where a person claims to have left Ireland mid-year while retaining Irish ties, or arrived while still resident elsewhere, the return now records the claim in a form Revenue can test. The residency position is no longer an assumption sitting behind the numbers; it is a declared item.

Why this is risk-profiling, not paperwork

Read together, the three changes are not administrative tidying; they are Revenue building a structured, comparable record of the positions that carry the most tax at stake. A deferral, a relief, an excess contribution, a residency claim: each used to be recoverable only by reading a computation or asking a question. Each is now a field. Fields can be sorted, matched across years, and flagged by software, which is what a modern tax authority does before it decides where to look.

The practical effect for a founder is that the future is being pre-profiled. A Retirement Relief deferral declared on the 2025 return sets an expectation that Revenue will check against the year the deferred tax is due. An Entrepreneur Relief claim recorded in a structured field is a claim that can be tested against the qualifying conditions. A split-year claim itemised on the return is a claim whose facts can be revisited. The room to take a position one year and quietly adjust it later narrows every time a free-text note becomes a mandatory field. The correct response is not to fear the form but to file it as though it will be read closely, because increasingly it will be.

What to get right before you file

Filing the 2025 Form 11 well is now an exercise in consistency, not just accuracy. Three things repay attention before the return goes in. First, reconcile the capital gains history: any deferral claimed in an earlier year, and any relief claimed now, should be traceable to its facts and to the conditions it depends on, because the form now carries the deferral forward and will surface it when it falls due. Second, check the employer pension position: if a company contribution to a PRSA exceeded 100% of emoluments in 2025, the excess belongs in the taxable income field, and it is better to report it correctly than to have it reconstructed later. Third, document the split-year facts: the dates, the ties, and the position on the other side of the move, so the claim on the return matches the reality and the corresponding foreign filing.

The deadline is 31 October 2026, extended into November for ROS filers who both pay and file online, and the Irish return sits alongside the founder's other corridor obligations rather than in isolation. Getting the disclosures right the first time is far cheaper than explaining an inconsistency to Revenue two years later.

Frequently asked questions

What changed in the Irish 2025 Form 11?

Revenue eBrief 127/26, published on 31 August 2026, sets out the changes, with the full detail in Tax and Duty Manual Part 38-01-04J. The most significant for founders and cross-border individuals are new capital gains tax fields for deferrals, reliefs, and tax previously deferred now due; a requirement to enter excess employer PRSA contributions in the taxable income field; and a requirement to give details where split-year treatment is claimed. The form has been available since 1 January 2026 and is filed by the usual pay and file deadline.

What is Revenue eBrief 127/26?

It is the Revenue notice, dated 31 August 2026, that announces and summarises the changes to the 2025 Form 11 income tax return. It points to Tax and Duty Manual Part 38-01-04J for the detailed list of amendments, paragraph by paragraph. It is the primary source for what the 2025 return now requires, and it is the document a practitioner should read before completing the form for a client with reliefs, deferrals, or a residency change in 2025.

How do I report a CGT deferral or relief on the 2025 Form 11?

The 2025 capital gains tax panel has new fields for claims to defer payment, claims to reliefs, and tax previously deferred that is now due, described in paragraphs 12.1 and 12.2 of the manual. A relief such as Revised Entrepreneur Relief is recorded as a relief claim, and a deferral such as the Retirement Relief deferral on a transfer to a child is recorded as deferred tax, with a dedicated field for a deferral that has since fallen due. The point is that the deferral is now carried forward on the return and matched to the year it crystallises.

How is excess employer PRSA contribution reported now?

Where an employer's contribution to an employee's PRSA exceeds the maximum, the amount above the limit must be entered in the gross amount of taxable income field on the PAYE, BIK and pensions panel, per paragraphs 5.2 and 8.1 of the manual. Since 1 January 2025 a tax-relieved employer PRSA contribution is capped at 100% of the employee's emoluments, and the excess is a taxable benefit. The 2025 return is the first on which that excess is declared directly as income rather than dealt with separately.

What is split-year treatment and why does the form now ask about it?

Split-year treatment, under section 822 TCA 1997, lets an individual arriving in or leaving Ireland during a year be treated as resident only for the part of the year tied to their Irish presence, so employment income earned outside that period is outside the Irish charge. Paragraph 7.2 of the manual now requires details on the return where the treatment is claimed against 2025 income. It matters because the claim depends on the facts of the move, and those facts have to line up with the individual's residence position in the other country.

When is the 2025 Form 11 due?

The pay and file deadline for a 2025 income tax return is 31 October 2026, with the customary extension into November for taxpayers who both pay and file through the Revenue Online Service. The specified return date is 31 October in the year after the year of assessment, or later where the return is filed electronically through ROS. Filing late exposes the taxpayer to a surcharge on the tax due, so the deadline should be worked back from, not toward.

Does this affect non-residents and people who left Ireland in 2025?

Yes, in two ways. Anyone claiming split-year treatment for 2025, typically because they arrived in or left Ireland during the year, must now give details of that claim on the return. And anyone who deferred capital gains tax or claimed a relief while resident, then moved, carries that deferral forward into a form that now tracks it. For a person moving along the Ireland, UK and UAE corridor, the 2025 return is where the Irish side of the residency and capital gains position is now pinned down.

Is this a new tax or just a reporting change?

It is a reporting change, not a new tax. The rates, reliefs, and residency rules are unchanged by eBrief 127/26; what has changed is how much of your position you must disclose, and in what structured form. That distinction matters because the risk it creates is not a higher bill but a higher chance of a mismatch being noticed. The reliefs and deferrals themselves are analysed in the related articles on Revised Entrepreneur Relief, Retirement Relief, and the employer PRSA limit.

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Critical advisory. The 2025 Form 11 now records capital gains deferrals and reliefs, excess employer pension contributions, and split-year residency claims in structured fields that Revenue can compare across years and test against the conditions each position depends on. For a founder who has claimed a relief, deferred a gain, run an employer pension contribution, or moved into or out of Ireland during 2025, the return is where those decisions become visible and durable, and an inconsistency is far more expensive to explain after filing than to get right before. If your 2025 position involves a business disposal, a Retirement Relief or Entrepreneur Relief claim, a large employer PRSA contribution, or a residency change across the Ireland, UK or UAE corridor, have the disclosures reviewed against the underlying facts, and against your filings on the other side of the move, before the return is submitted. That review is one we provide, coordinated across Revenue and HMRC positions. Speak to us before you file, not after Revenue asks.