With just under four months to go to the commencement of Making Tax Digital (MTD) for income tax from 6 April 2026, the Institute is pleased to present our new MTD hub. The aim of the hub is to assist members and businesses in their preparations for this key change in UK tax administration. Read the latest news and guidance on this key change in addition to more detailed information on what MTD for income tax is, the timetable for mandation, exemptions, deferrals, how to sign up and much more. The Institute will continue to develop the hub in the coming weeks and months as policy changes are announced and as HMRC publishes tools and information to assist agents, businesses and landlords in their preparations.

The guidance on the interest limitation rule has been updated by Revenue to provide details in relation to the ‘association’ tests in the context of partnerships. The guidance is consistent with the relevant information included in the guidance on the anti-hybrid rules and guidance on the taxation of partnership. An additional appendix has been included to provide clarifications on the population of the Form CT1 with respect to the interest limitation rules.

The Central Statistics Office has published the Quarterly National Accounts for the third quarter of 2025 confirming GDP decreased by 0.3 percent in the third quarter of this year while Modified Domestic Demand grew by 2.3 per cent in the quarter. The publication outlines that exports increased by 2.1 percent while total imports rose by 10.4 percent. Personal spending on goods and services which is seen as a key measure of domestic economic activity, was up by 0.1 percent in the quarter. Commenting on the figures, Tánaiste and Minister for Finance, Simon Harris said: “Today’s figures confirm the continued resilience of the domestic economy. Modified Domestic Demand grew by 5 per cent in the third quarter on an annual basis. While this may overstate the underlying performance of the economy at present, I am encouraged by the strength of consumer spending which grew by 2½ per cent over the same period.  Alongside the robust exchequer figures released yesterday, today’s figures highlight the relatively healthy position of our domestic economy at present.”

Last week saw the House of Commons debate the Budget resolutions following which the Finance Bill was published and introduced to the House. Finance (No. 2) Bill 2025/26 had its first reading last week with second reading subsequently scheduled for 16 December 2025. The Bill, as introduced, contains the legislation for a range of announcements in November’s Budget but also features the draft legislation on the changes to agricultural property relief and business property relief from 6 April 2026. Explanatory notes to the Bill are also available. The House of Commons Library has also published a research briefing on the Autumn Budget 2025 and the Finance Bill.  The Finance Bill also includes the primary legislation for the UK’s carbon border adjustment mechanism legislation (CBAM) which will commence from 1 January 2027. More information on the UK’s CBAM is available in a policy update and factsheet. Finance (No. 2) Bill 2025/26 also includes further amendments to the UK's Pillar Two multinational top-up tax and domestic top-up tax. According to HMRC, these amendments are “those identified from stakeholder consultation or otherwise necessary to ensure the UK’s legislation remains consistent with the commentary and administrative guidance to the GloBE rules developed by the UK and other members of the OECD/G20 Inclusive Framework”. HMRC has also confirmed that the Finance Bill does not include any amendments to reflect any ‘side-by-side package’ as this is still being finalised by the Inclusive Framework. The ‘side by side package’ is a proposed political agreement which would allow the existing Global Intangible Low-Taxed Income Tax regime of the USA to coexist with the OECD's Pillar Two global minimum tax rules. The objective of this arrangement would be to exempt US parented multinational enterprises from some key Pillar Two rules.

The Pillar Two registration deadline for in-scope entities with a fiscal year ending on or before 31 December 2024 is 31 December 2025. At a recent Main TALC meeting, Revenue’s Large Corporates Division (LCD) highlighted that the number of registrations to date remains low. Revenue outlined the importance of completing registrations well ahead of the deadline and urged practitioners to ensure that any clients within the scope of Pillar Two are registered on time. Revenue had previously sent a letter to Irish companies who may be in scope of Pillar Two taxes, advising them of their registration obligations. The Pillar Two registration link can be found on the ROS homepage under ‘Other Services’. Further details are outlined in an earlier newsletter item.

Revenue has published a further warning of fraudulent emails, SMS (text messages) and phone calls seeking personal information from taxpayers. The press release outlines that Revenue has recently had sight of scam emails which claim that a taxpayer is “due an audit” and which include a link requesting the taxpayer to arrange the audit by a specified date. These messages are not from Revenue. Revenue will never contact a taxpayer by email, SMS or phone call to inform you of a tax refund or bill. Taxpayers who have provided Revenue account details in response to an email, SMS or phone call are advised to reset their password immediately. Taxpayers are advised to contact their bank or credit card provider if they have provided bank or card details.

Following the Budget, HMRC sent an email setting out key details that will directly affect tax agents, in addition to information that might be useful for their clients, or which agents may receive enquiries about. HMRC also confirmed that as set out at the Budget, the Finance Bill includes the legislation that requires tax advisers who interact with HMRC on behalf of clients to register with HMRC and meet certain eligibility conditions. This requirement was due to take effect from April 2026 but has now been delayed to take effect from May 2026. HMRC expects to publish detailed guidance on this next month. Chartered Accountants Ireland responded to the consultation on the draft legislation for this measure in September and had recommended that the measure be delayed. Our submission also recommended that the meaning of tax adviser be restricted to only require those at the highest level working in tax to be within the scope of the rules. The draft legislation now published confirms that this recommendation is largely being implemented for organisations with more than six officers (as defined). Officer is defined as follows: “(a) in relation to a company, a director; (b) in relation to a body corporate whose affairs are managed by its members, a member who exercises functions of management with respect to it; (c) in relation to a body corporate not within paragraph (a) or (b), an officer of the body whose functions correspond to those of a director of a company; (d) in relation to a partnership, a partner; (e) in relation to any other organisation, a person who exercises functions of management with respect to it.” Clauses 222 and 223 of the Finance Bill sets out details of the application process and who within that process is a relevant individual and officer whose details must be included in the application for registration.  More details are available in the associated policy paper which confirms that there will be a three-month transition period. Further details on registration timelines and the transition arrangements for specific tax adviser groups will be communicated by HMRC to stakeholders in advance. The Institute has been engaging with HMRC in the previous weeks and months as HMRC developed this amended draft legislation and will continue to do so.

Revenue has updated its guidance on deposit interest – whether a trading receipt to outline when deposit interest can be treated as a trading receipt. The guidance confirms that to qualify as a trading receipt, the funds must be considered an integral aspect of the trade. The guidance also clarifies that in general, interest earned on funds placed on deposit, which are deemed to be in excess of a company’s business needs, are not considered income taxable under Case I. This is on the basis that Revenue deems such funds as not being integral to the company’s trading activities.

Revenue has updated its guidance on small, self-administered pension schemes in relation to references in the document to Pensions Branch, High Wealth and Financial Services Division. Certain references to tangible moveable asset have also been updated and the guidance now includes the deemed distribution provisions.

Revenue has updated its guidance for trading lessors of certain short life plant and machinery. The general guidance on finance and operating leases has now been moved to the guidance on the Leasing of Machinery or Plant: General Principles of Taxation. In addition, certain outdated material relating to the taxation of specified assets has been removed.

The Government made two announcements at the Budget as part of its ongoing Tax Administration Framework Review (TAFR) project on the correction of errors (there will be a consultation in 2026 on new HMRC powers obliging taxpayers to correct inaccuracies where they are identified) and reform of behavioural penalties. HMRC subsequently sent a detailed update on the next steps for both of these in addition to its ongoing dispute resolution reform work. Earlier in the year Chartered Accountants Ireland responded to the associated consultations on new ways to tackle non-compliance (which contained the proposals on correction of errors) and reform of behavioural penalties. On modernising the correction of errors, HMRC is progressing work on key design elements of the proposals, including the introduction of a general obligation to correct. According to HMRC, the feedback received through this consultation indicated that this measure would be a welcome addition, hence legislation will be drafted for stakeholder input which will take place via bespoke sessions in early 2026. On behavioural penalty reforms, HMRC is currently working through the detailed policy design, including some of the operational practicalities, ahead of moving onto drafting legislation. As this work continues, it will bring up policy choices which HMRC will discuss with stakeholders ahead of publishing any draft legislation.  HMRC has also been analysing the responses received to the consultation on improving HMRC's approach to dispute resolution and is continuing to develop options and prepare a summary of responses for publication. HMRC is also working on launching a new quarterly update which will provide more regular TAFR news; the first edition is currently in development.

The guidance on the income tax treatment of married persons and civil partners has been recently updated by Revenue providing additional information including  details on the three bases of assessment for married couples and civil partners. The relevant updates to the document are: The increase in the standard rate tax band and tax credits, as provided for by Finance Act 2024 and effective from 1 January 2025, with the examples throughout the guidance updated accordingly.   Paragraph 1.1 has been inserted to provide a tabular style summary of the three bases of assessment available to married couples and civil partners. Paragraph 4.2 provides additional guidance on the application of joint assessment and the nomination of the assessable spouse or civil partner. Paragraph 5.2 includes further clarifications on cases where both spouses or civil partners are non-resident, and one spouse or civil partner has income chargeable to tax in Ireland. A new example has been included to outline the tax treatment of a married couple who separate.