HMRC has recently opened two consultations which will affect companies. As reported previously, the consultation ‘Modernising and standardising company tax returns’ is open until 4 June 2026 and ‘Reporting company payments to participators - modernising the reporting framework’ is open to 10 June 2026 with responses to be submitted via an online form. On the latter consultation, it is likely to be extremely challenging for HMRC to receive feedback from smaller companies, therefore we believe that the responses from the Professional Bodies, including Chartered Accountants Ireland, will be crucial to properly target any changes. We’d like to hear your views on each of these consultations by close of business on Friday 8 May 2026 by email to tax@charteredaccountants.ie. Both consultations were first announced at the 2025 Autumn Budget last November. Chartered Accountants Ireland has already discussed its initial concerns about close company reporting with HMRC in a meeting last December. Reporting company payments to participators - modernising the reporting framework According to this consultation, close companies would report details of transactions with participators to HMRC. The Government believes that the close relationship between close companies and its participators means that there is an increased risk of tax loss for the Exchequer. Although anti-avoidance legislation is already in place to prevent this, the Government is concerned that HMRC “is not receiving the full picture in terms of how close companies interact with their participators”, and that further action is required to prevent “error and evasion” and reduce the small business tax gap.  The consultation also asks a number of questions about the current rules, including how well understood the close company and loans to participators rules are among the small company population. There are also questions about how small companies currently keep records of transactions with participators, and where they get advice from. It is highly likely that these proposals are being introduced as an alternative to Making Tax Digital for Corporation Tax which the Government announced at the Autumn Budget 2025 will not be implemented. The consultation proposes that close companies will be required to provide detailed information on a wide range of transactions with participators, including: any payments whether by cash, card, bank transfer, or other method, sales/purchases of assets to/from the company, dividends and other distributions, any other transfers of value from the company to a participator, and any repayments, write-offs or releases of loans to participators.  For each transaction the information to be reported would include the recipient’s identity, and the amount and date of each transaction. Currently, the only exception being considered is where information is already reported to HMRC under Real Time Information, for example, directors’ salaries or payrolled benefits. The consultation does not set out details on the frequency of reporting but does suggest that this could be an annual cycle tied in with the company tax return. However, there are references to more regular or potentially even real-time reporting which would be extremely burdensome and challenging. Methods of reporting suggested in the consultation include updates to the CT600A or company tax return, or a bespoke digital solution.  The consultation says that any new requirements should not introduce disproportionate burdens on companies and should build on existing record-keeping. Modernising and standardising company tax returns This consultation seeks views on: the proposed implementation timescales and enforcement options for prescribing the format, content and data tagging of Corporation Tax computations, and mandatory online filing of amended company tax returns. The consultation sets out exemptions that would apply to mandatory online filing of amendments and seeks views on whether any additional exemptions should be considered. It also asks whether, for practical reasons, mandation should commence later than 1 April 2027.

In this week’s detailed miscellaneous updates which you can read more about below, HMRC has sent a message on multi-factor authentication for tax advisers. In other news this week: HMRC has published the advisory fuel rates applying from 1 March 2026 for employees using a company car. We issue a reminder that from 1 April 2026, companies will be required to use commercial software to file company tax returns because HMRC and Companies House free software will no longer be available, The latest HMRC Stakeholder Digest and HMRC Agent Update 141 are available, HMRC has responded to the Adjudicator’s 2024/25 annual report, HM Treasury has announced a review of approved mileage allowance rates which have been unchanged since 2011, and With the price of chocolate skyrocketing whilst the size of Easter eggs are shrinking, HMRC has issued a Press Release on saving Easter childcare egg-spenses with Tax-Free Childcare. Multi-factor authentication for tax advisers HMRC has asked us to share the below message on changes to the agent’s sign-in journey. “HMRC Multi-Factor Authentication (MFA) – Change to theagent signin journey  HMRC are working closely with tax advisors and professional bodies to introduce Multi-Factor Authentication (MFA) to strengthen security on agent accounts. MFA will provide greater protection as agents sign in to HMRC’s services, helping to keep accounts and client data secure.   From Tuesday 7 April, to raise awareness of the upcoming introduction of MFA, agents will see a new page when signing in to their HMRC account on GOV.UK, linking to further guidance in the Tax Agent’s Handbook.  A small group of agent volunteers are currently participating in a period of MFA test and learn, with testing then due to expand in April. HMRC will be contacting agents who they recognise would benefit from early adoption of the additional security MFA offers. This may be agents who have previously contacted HMRC due to account suspension or to raise security concerns.   Members using automated processes or third-party software for their sign-in journey should check whether any software updates are needed and allow time for those adjustments. These changes only apply to web sign in on GOV.UK and will not affect services such as PAYE or Making Tax Digital for VAT. We urge agents to prepare and depending on their circumstances, identify the best approach for them to manage MFA’s introduction.  To give agents time to prepare, HMRC will confirm the MFA go-live date for the wider agent community as early as possible, currently scheduled for delivery by the end of June 2026, but subject to successful testing.”  

In this week’s cross-border trading corner, we bring you the latest guidance updates and publications. The most recent Trader Support Service bulletin is also available as is the latest Brexit and Beyond newsletter from the Northern Ireland Assembly EU Affairs team. The minutes and slides from the most recent meeting of the HMRC Stakeholder Forum, the Northern Ireland Joint Customs consultative Committee (which the Institute is represented on) are available together with ICS2 groupage HMRC guidance. Miscellaneous guidance updates and publications This week’s miscellaneous guidance updates and publications are as follows: Appendix 2 C21e: Data Element 1/11: Additional Procedure Codes, Additional Information (AI) Statement Codes for Data Element 2/2 of the Customs Declaration Service (CDS), CDS Declaration Completion Instructions for Imports, Previous document codes for Data Element 2/1 of the Customs Declaration Service, Known error workarounds for the Customs Declaration Service (CDS), Tax types for Data Element 4/3 of the Customs Declaration Service, Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service (CDS), Maritime ports and wharves location codes for Data Element 5/23 of the Customs Declaration Service, National additional codes to declare with Data Element 6/17 of the Customs Declaration Service, UK Trade Tariff: duty suspensions and autonomous tariff quotas, Declaration Unique Consignment References, Entry in the Declarant's Records, Simplified Declaration Process, Simplified Customs Declaration Process, Get customs data for import and export declarations, Report a problem using the Customs Declaration Service, Procedures Codes and Additional Procedures Codes, Supplementary Declarations, Introduction, and Internal temporary storage facilities (ITSFs) codes for Data Element 5/23 of the Customs Declaration Service.

The European Commission has welcomed the agreement between the European Parliament and the Council to a reform of the EU Customs Union. The reform will establish a new single EU customs data hub which will digitalise and simplify procedures while tightening controls on non-compliant, dangerous or unsafe goods. Overall, the new system should allow for more robust controls without an excessive burden for authorities and traders.

Revenue has published a further warning of fraudulent emails, SMS (text messages) and phone calls seeking personal information from taxpayers. Revenue has updated its website to highlight recent fraudulent emails claiming that taxpayers are ‘due an audit’ and directing them to click a link to schedule the audit by a specified date. Examples of fraudulent emails and text messages are included in the communication. 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.

Revenue has updated its guide on how to protect your business from becoming involved in VAT fraud providing examples of relevant due‑diligence actions which can be undertaken when establishing a trading relationship with a supplier or customer.

The Tax and Duty manuals on  Revenue Information Powers and the Schedule of Revenue Powers have recently been updated to provide additional clarifications and to outline Revenue’s approach in exercising the relevant legislative powers. The guidance on Information Powers outlines that Revenue will notify a taxpayer in writing where a notice has been issued to a third party under section 902 TCA 1997 or to a financial institution under section 906A TCA 1997. The guidance on the schedule of Revenue powers now includes a reference to section 109A VAT Consolidation Act 2010 which empowers Revenue to require a taxable person who is not established in the EU to appoint an EU‑established tax representative. That representative will be responsible for the payment of any VAT arising from the supplies made by the taxable person within the State.

Revenue has updated its guidance on the operation and administration of the Pillar Two rules. The revised material provides additional detail and clarification on the application of the rules, offering further insight into how they are to be interpreted and implemented in practice. The relevant sections of the guidance on the operation of Pillar Two which have been updated are as follows: Section 5.1, to update guidance in respect of ultimate parent entities. Section 6.10, to update guidance in respect of section 111N - Calculation and allocation of UTPR top-up tax amount, as it relates to the allocation of UTPR among domestic constituent entities. Section 7.2, to update guidance in respect of intra-group financing arrangements and use of losses carried forward. Section 8.5 (section 111X – Total deferred tax adjustment amount) and section 12.1 (section 111AW – Tax treatment of deferred tax assets, deferred tax liabilities and transferred assets upon transition), as it relates to the utilisation of loss deferred tax assets, Section 9.6, to update guidance in respect of section 111AH - Minority owned constituent entities, as it relates to an orphan entity that is a constituent entity, Section 9.7 (section 111AI - Qualified domestic top-up tax safe harbour), Section 9.8 (section 111AJ - Transitional CbCR safe harbour) and section 12.1 (section 111AW – Tax treatment of deferred tax assets, deferred tax liabilities and transferred assets upon transition), as it relates to the treatment of certain deferred tax assets (DTA’s) arising from tax benefits provided by General Government, Section 13.3, to update guidance in respect of section 111AAC - Chargeable entities, as it relates to the reallocation of any QDTT calculated for a securitisation entity that is a minority owned constituent entity, and Section 13.4, to update guidance in respect of Section 111AAD - Determining top-up tax amounts of qualifying entity, as it relates to the application of the local accounting standard in calculating domestic top-up tax, in certain circumstances, notwithstanding that the fiscal year end does not align with that of the ultimate parent entity. The changes to the guidance on the administration of Pillar Two rules include: Updates with respect to the requirements of the Directive on Administrative Cooperation and the OECD Pillar Two Multilateral Competent Authority Agreement (MCAA), An update to reflect that the secondary collection mechanism for UTPR and QDTT liabilities do not apply to a securitisation entity in certain circumstances, and Updates with respect to the taxpayer obligation to keep records, the provision of related penalties for non-compliance, and Revenue’s power to inspect records. Several other minor amendments have been reflected throughout both documents.

Revenue has published updated guidance on the participation exemption for certain foreign distributions to reflect amendments contained in Finance Act 2025. Information on distributions‑in‑specie and how the tax deductibility of a distribution impacts the exemption claim are also included in the guidance. In general, for the purposes of the exemption, a relevant distribution does not include a distribution, or part of a distribution, that has been, or may be, deducted for tax purposes in any territory outside the State under the law of that territory. The guidance confirms that, from 1 January 2026, a distribution will not be excluded from being a relevant distribution solely because it is deductible for the purposes of a tax comparable to the close company surcharge in section 440 TCA 1997. Section three of the guidance, which outlines the conditions the foreign dividend-paying company must meet to qualify as a relevant subsidiary, has been updated to include the following information: Relevant distributions made on or after 1 January 2026 by a company resident in a non-EEA or non-tax treaty territory are in scope of the exemption if foreign withholding tax at a nominal rate greater than zero per cent is paid on the full amount of the distribution and not refunded. The definitions of “relevant period” and “reference period” are reduced from five years to three years, reducing the period in which a company must be resident in a relevant territory, or have not had certain excluded merger and acquisition activity, prior to making a distribution. In cases where the domestic law of a relevant territory does not determine a company’s residence, the residence position will be determined under the terms of the relevant territory’s tax treaty with Ireland. A company resident in a territory with which Ireland has a newly signed tax treaty is eligible to qualify as a relevant subsidiary from the date of signature of that tax treaty. In the case of a relevant distribution made on or after 1 January 2025, a distributing company is permitted, during the reference period, to have acquired a business or business assets consisting of shares, or to have moved residence from Ireland, or to have had merger and acquisition activity involving an Irish resident company.

Revenue has updated its guidance on termination payments with an additional example in paragraph 3.3.1. The example relates to unpaid protective leave and confirms that such leave does not constitute a gap or break in service when calculating complete years of service for the purposes of any potential relief available. The guidance also explains that protective leave includes carer’s leave, maternity leave, and parental leave.  

Revenue issued a press release last week confirming that Local Property Tax (LPT) returns and payments have been now made for over 1.9 million properties, as part of last year’s revaluation process. However, the statistics show that returns in respect of approximately 390,000 properties remain outstanding, albeit payment arrangements are in place in respect of 227,000 of these properties. Revenue is requesting all residential property owners who have not filed an LPT return to do so immediately. Revenue has advised that it will be writing to non-compliant property owners as part of its LPT compliance campaign. For property owners who have not yet made arrangements to pay their 2026 liability, a range of flexible payment options remain available including payment by direct debit or salary deduction over a reduced ten-month period, or alternatively a single annual deduction. Compliance letters will shortly issue to property owners in employment where a return has not been filed or where a payment arrangement is not in place. Property owners in this category will be given a two‑week deadline to submit their return and payment. If they fail to do so, Revenue will instruct their employer to begin deducting LPT from their employment income. Further correspondence will issue in due course to other categories of property owners. For the 227,000 property owners who have payment arrangements in place but have yet to file a return, Revenue is requesting these property owners to file their LPT return and update their valuation band as failure to do so will result in enforcement action. Revenue’s website includes an interactive valuation tool to assist property owners in assessing the value of their property which is intended as a guide only. We have outlined further relevant details in our earlier newsletter item. Updated property statistics are available on the Revenue website and includes the latest data for LPT, Vacant Homes Tax and Residential Zoned Land Tax.

In last week’s Tax Newsletter, we notified readers that we received an invitation to present before the Joint Committee on Finance, Public Expenditure, Public Service Reform and Digitalisation, and Taoiseach as part of the pre-legislative scrutiny of the Finance (Tax Appeals and Fiscal Responsibility) Bill 2025. You can now watch that session in full here. The invitation was received following our submission to the Committee in December. In our opening statement and in response to the questions raised by the Committee, we highlighted two fundamental concerns with the proposals in Head 5 of the Revised General Scheme of Finance (Tax Appeals and Fiscal Responsibility) Bill 2025, being the protection of taxpayer privacy and the shifting of power too far toward the State. We expressed our unequivocal support for the protection of taxpayer privacy, and our position is that the right to elect for a private hearing should be preserved at the Tax Appeals Commission as a court of first instance. Tax appeals often involve deeply sensitive personal and financial information. For over a decade, taxpayers have had the right to request a private hearing at the TAC, with anonymised determinations still published to ensure transparency and accountability to the public. The legal principles underscoring a determination of the TAC are available to the public as it stands. Further, the nature of a Tax Appeal is that all information is provided at the outset of an appeal. A key reason for administering justice in public is to enable the public to provide information to ensure justice can be achieved. However, in the case of tax appeals, this requirement has already been satisfied by the legal obligations of taxpayers under the Tax Acts. There obligations demand complete transparency of all financial information to Revenue for the purposes of filing an accurate and complete tax return. We also expressed our grave concerns that shifting balance of power toward the State risks undermining the spirit of voluntary compliance that underscores the entire self-assessment model. Removing the taxpayer’s right to elect for a private hearing risks deterring compliant taxpayers from seeking independent adjudication of Revenue’s legal interpretations thereby eroding trust and transparency and undermining confidence in the overall appeals process.  Paradoxically, those who deliberately default may still protect their privacy where they are seen to cooperate with Revenue, while compliant taxpayers will now likely lose that right in most cases. The proposed amendments draw on the Supreme Court’s decision in Zalewski v the Workplace Relations Commission. However, that case involved an absolute ban on public hearings; the Tax Appeal Commission is already public by default. The proposals go far beyond what the Constitution requires—and in doing so, places taxpayer rights in the hands of a quasi-judicial body, rather than preserving the longstanding statutory protections afforded to compliant taxpayers. At a time when voluntary compliance underpins our self‑assessment system, it is vital that taxpayers retain a meaningful, reliable right to privacy in tax matters. The proposed amendments would significantly undermine that principle.