Revenue has extended the deadline for the completion and submission of the EWSS Eligibility Review Form in respect of June 2021 to 15 August 2021. The eligibility review form in respect of July 2021 is also due to be submitted on the same date.   The CCAB-I made a submission to Revenue last Friday on foot of representations from members to call for an extended EWSS Review Form deadline.  In a letter in response to the CCAB-I’s submission, Revenue set out that in so far as monthly turnover figures cannot be readily accessed for the purpose of completing the EWSS Eligibility Review Form, businesses may use the average turnover as derived from their bi-monthly (or other periodic) VAT return data to calculate the monthly turnover value for the review form.   

In its response to the Call for evidence: timely payment, the Institute is not supportive of mandated real time payments of income tax and corporation tax. The Institute, under the auspices of the NI Tax Committee, made a number of recommendations in its response including that HMRC should set aside the current conversation on mandation of real time tax payments and should instead explore less challenging payment solution changes. The following recommendations were also made:- The conversation on real time payment of tax should take a step back to focus initially on voluntary payments – however this should only take place once up to date evidence and analysis, including wider discussions with UK businesses and taxpayers is conducted by HMRC, This should explore the appetite for voluntary payment and clearly set out the case for moving to real time payments which should be the last stage in the UK’s move to its version of Tax Administration 3.0; HMRC should provide an update on the outcomes from building into its systems and messaging functionality which compares in-year tax calculations with payments on account due; and Tax complexity continues to be a very serious issue which not only threatens the ability of the UK Government to meet its 10 year tax administration strategy but is also a serious impediment to successful further and future digitisation of the UK tax system starting with MTD for income tax in 2023 - a defined roadmap to tackle tax complexity, beginning with income tax first must therefore be established as a matter of urgency. Although this Call for evidence is badged as the opening of a conversation in this area with no decisions yet taken, it is clear that the Government is keen to move to a real time tax payments system in the future. The Institute will continue to put forward members views on this issue.  

According to new analysis from EY, GDP is not necessarily a good measure of how well a society is doing – and specifically, how well a country fares after the pandemic. Yannick Cabrol and Simon MacAllister suggest other considerations. Economists and public decision-makers have been relying too long on GDP to measure the health of our society. GDP assesses the overall size of the cake and excludes social indicators, which can lead to mistaken conclusions. After all, if a doctor checks someone’s temperature with the wrong tool, they may not make the proper diagnosis or propose the right treatment. Below are areas that must be considered when thinking about the impact of the pandemic on Ireland. The vulnerable At the onset of the pandemic, particularly during the initial lockdown, there was a great emphasis on the sentiment that “we are all in this together”. However, over the last 12 months, this has ceased to be the case. Instead, the pandemic had a greater impact on those already vulnerable, while others benefitted. Social inequalities The impact of the pandemic is very different to that of the financial crisis of a decade ago. But one area of similarity is that the burden of impact has fallen more acutely on the most economically disadvantaged in society. The health outcomes mimic the economic ones, with people in disadvantaged areas more likely to contract COVID-19 or suffer job loss or severe disruption. The disease itself has disproportionally affected the poorest people in our societies. In Ireland, those considered very disadvantaged are almost 50% more likely than the average citizen to contract the virus, while the most affluent are 30% less likely to contract the virus. Geographical inequalities Residents of Irish cities are 32% more likely to contract COVID-19. This can be explained by higher population densities, increased levels of social interaction, and the prevalence of younger, more mobile communities. This presents significant difficulties for decision-makers. Public health regulations need to be clear and simple to follow, but a centralised approach can sometimes be perceived as unfair and excessive for areas with lower incidence rates. The future will be shaped by diversity – of working patterns, of place, and of individuals. Technology will open new possibilities for towns and rural economies, and cities will become more time fluid with a greater emphasis on entertainment and socialising and less on routine and homogeneity. Sectoral inequalities Economic commentary and policy formation tends to focus on the exporting industries that are key to driving growth. But the pandemic has shone a light on the industries that form the backbone of the labour market: our public services and retail, leisure and entertainment industries. While public services have been among the least disrupted sectors, the accommodation, retail and entertainment sectors have endured a very difficult year. Lower paid jobs have been the most disrupted by COVID-19. The pandemic impacted nearly 90% of jobs in the hospitality sector at some point in 2020. Workers in that sector already had the lowest weekly earnings pre-COVID, at around €376 per week. Financial inequalities Unlike during the last major global recession, the main drivers of wealth – namely, stock prices and housing – have held up very well. The stock market performance reflects the acceleration of digital business models and the success of businesses in sectors such as information and communications technology and healthcare. As a result, COVID-19 has exacerbated the mismatch between the labour market and the stock market. In 2020, stocks increased by 15%, while the number of people employed decreased by 18% (excluding those temporarily supported by the Government). The result is increased financial inequalities. The pandemic is benefitting the few who have financial assets while disadvantaging the many who are struggling to keep or find a job. Those who have been able to work from home also managed to save more money than ever in 2020. The Central Bank of Ireland reports that Irish households saved over €14 billion in the year to December 2020, with total Irish household deposits reaching a record €124.5 billion at the end of the year. This contrast in wealth and labour market outcomes is just another example of disruption causing division and creating a disconnect between winners and losers. International inequalities Interestingly, more equal societies appear to be doing better in their fight against COVID-19. This may be linked to a greater willingness to invest in public health infrastructure as well as a commitment to delivering better living conditions for disadvantaged people. A fairer society is a goal sought by almost every economy in the world. However, the rewards for achieving such a goal have often been the subject of heated debate. Does a greater redistribution of wealth curtail an economy’s ability to grow or enhance it? Perhaps the impact of the pandemic will provide another reason, if one was needed, to strive for a fairer society. Yannick Cabrol is EY-DKM Economic Advisory Services Assistant Director in EY. Simon MacAllister is Strategy and Transactions Partner and Head of Valuation, Modelling and Economics in EY.

Through a new campaign, “1,000 Chartered Accountants”, launched today, Chartered Accountants Ireland, The Institute of Chartered Accountants in England and Wales (ICAEW), and The Institute of Chartered Accountants of Scotland (ICAS) are calling for 1,000 Chartered Accountants from within their memberships to commit to leading change by championing the UN Race to Zero campaign.   The professional bodies will promote and support these 1,000 Chartered Accountants who have committed to beginning their journey to net-zero carbon emissions by leading the way in their own organisations or by helping a client on a net zero journey. Commenting, Chief Executive of Chartered Accountants Ireland, Barry Dempsey said “Six years on from the Paris Agreement, the urgency of the climate crisis requires drastic action. This can be seen from the European Commission’s ‘Fit for 55’ packaged announced yesterday, the most ambitious multilateral climate strategy to date.  “Ambition needs to be translated into action and we are delighted to join ICAEW and ICAS in the “1000 Chartered Accountants” campaign. Accountants are uniquely placed to drive progress on sustainability on the ground in organisations. They make critical financial decisions daily about purchasing, procurement and many other things and the information they provide is vital to wider decision-making. From this position of influence comes opportunity and responsibility.” In committing to the campaign, signatories are pledging to reach net zero GHG emissions as soon as possible, and by 2050 at the latest, in line with global efforts to limit warming to 1.5C. Within 12 months, they must explain what actions will be taken toward achieving both interim and longer-term pledges, especially in the short- to medium-term. They are also required to report publicly both progress against interim and long-term targets, as well as the actions being taken, at least annually.  The UN Race to Zero campaign is an initiative of the United Nations Framework Convention on Climate Change ('UNFCCC'). It pulls together other initiatives from across the climate action community under a single umbrella to rally businesses, cities, regions, and investors to achieve a healthy, resilient, zero-carbon recovery - all goals of the Paris Climate Agreement - ahead of COP26 this November, at which governments will commit to being more ambitious in their climate action.  For more information and to join the 1,000 Chartered Accountants campaign, see.  ENDS      About Chartered Accountants Ireland Chartered Accountants Ireland is Ireland’s leading professional accountancy body, representing almost 30,000 influential members around the world and educating 7,000 students. The Institute aims to create opportunities for members and students, and ethical, sustainable prosperity for society. An all-island body, Chartered Accountants Ireland was established by Royal Charter in 1888 and now has members in more than 90 countries. It is a founding member of Chartered Accountants Worldwide, the international network of over one million chartered accountants. It also plays key roles in the Global Accounting Alliance, Accountancy Europe and the International Federation of Accountants.   Chartered Accountants Ireland members provide leadership in business, the public sector and professional practice, bringing experience, expertise and strict standards to their work for, and with, businesses in every sector. Chartered Accountants Ireland engages with governments, policy makers and regulators on key issues affecting the profession and the wider economy.  In Spring 2021, Chartered Accountants Ireland joined the United Nations Global Compact - the world’s largest voluntary corporate sustainability initiative. The Institute is committed to becoming the first carbon-neutral professional accountancy organisation in Ireland by measuring its carbon footprint and aggressively reducing its carbon emissions.  

While business performance has historically been measured in financial terms, over the past two decades reporting requirements have been changing rapidly. Societal awareness of environmental and social issues is increasing and, as a result, stakeholders are demanding a wider range of information with a clear global trend towards mandatory sustainability reporting. There are currently 614 sustainability reporting requirements across 84 countries and 25 Exchanges (covering 16,456 companies) require ESG reporting as a listing rule. Organizations are therefore relying on the knowledge, skills and processes of finance professionals, including the crucial role of the accountant, to get ahead of corporate reporting trends.  This guide, created by A4S and its Accounting Bodies Network (of which Chartered Accountants Ireland is one), offers a brief introduction to the changing corporate reporting landscape. It summarises recent key developments in sustainability reporting. It shows how it is impacting the role of the accountant and shaping the future of corporate reporting. It also highlights how this area is likely to evolve going forward, offering signposting to further sources of information. Download the guide in full here

Revenue released new guidance on the Employment Wage Subsidy Scheme (EWSS). This new guidance includes information on the extension of the EWSS from 1 July 2021 until 31 December 2021. A number of updates were also included in the Main EWSS guidelines. Section 28B of the Emergency Measures in the Public Interest (Covid-19) Act 2020, which provides for the operation of the EWSS, is to be amended by the Finance (Covid-19 and Miscellaneous Provisions) Bill 2021, and extends the EWSS until 31 December 2021. Revenue is currently operating the extension of the EWSS under care and management until such time as the legislation is enacted, so payment of the EWSS has not ceased. The Guidelines on eligibility for the Employment Wage Subsidy Scheme from 1 July 2021 provide details on the employer eligibility criteria for the extended period. An employer must be able to demonstrate that their business is expected to experience a 30 percent reduction in turnover or customer orders in the period 1 January to 31 December 2021 for pay dates from 1 July to 31 December, and this disruption is caused by COVID-19. This reduction in turnover or customer orders is relative to: the period 1 January to 31 December 2019 where the business was in existence prior to 1 January 2019; where the business commenced trading between 1 January and 31 October 2019, from the date of commencement to 31 December 2019; or where a business commenced on or after 1 November 2019, the projected turnover or orders for 1 January 2021 (or date of commencement if later) to 31 December 2021 as if the pandemic had not occurred. Employers are required to undertake a continued review of the eligibility on a rolling monthly basis comparing actual performance with projected performance over the period January to December 2021. Employers must complete and submit a monthly EWSS Eligibility Review Form through ROS. Initial submissions should be made between 21 and 30 July 2021. On the 15th day of every subsequent month employers will need to provide the actual results for the previous month together with reviewing the original projections provided to ensure they remain valid. A summary table of the information and due dates is included on page 7 of the guidance. Where an employer no longer satisfies the 30 percent test, they must deregister for the EWSS with effect from the first day of the month, or immediately where they become aware prior to the end of the month, and cease claiming the subsidy immediately. Employers can re-register where they become eligible again. Significant updates included in the Main Guidelines on the operation of the Employment Wage Subsidy Scheme are as follows: Page Update Rate of subsidy (page 18) The rate of weekly subsidy an employer has received per eligible employee since 20 October 2020 is unchanged until 30 September 2021. Consideration is being given to an employer contribution to employee wages from October 2021. Further clarity on this, together with the subsidy paid rates to be paid from 1 October 2021, will be provided in September 2021. Operation of payroll and processing of subsidy claims (page 23) Certain employers will be able to warehouse overpayments of EWSS, where they are unable to repay due to COVID-19 restrictions. Period 1 runs until 31 December 2021 – 0% rate of interest Period 2 runs from 1 January 2022 to 31 December 2022 – 0% rate of interest Period 3 commences on 1 January 2023 until warehoused debts are discharged – 3% rate of interest applies Other tax payments and filing obligations must be kept up to date for the duration of the debt warehouse period. Failure to meet such obligations will result in the withdrawal of the warehouse facility. Employers in Revenue’s Personal Division or Business Division will generally have their EWSS overpayments warehoused automatically. LCD and MED cases must make an application. Reduced employer PRSI rate of 0.5% (page 24) Every time an EWSS subsidy claim is paid, the PRSI credit element will then be posted to the employer’s online Statement of Account. When the employer’s PAYE (Employer) balance is calculated at the start of the following month, this PRSI credit is deducted from the outstanding PRSI balance due. This reduced liability is what becomes due and payable for the relevant month. An updated example has been provided. Publication (page 27) The names and addresses of employers who received the EWSS will be published in October 2021 and January 2022, in addition to the previous dates. Compliance checks (page 27) Revenue is undertaking real time checks of PAYE compliance of employers availing of the EWSS, and cross-referencing claim data against other Revenue data sources. Revenue is also carrying out a follow-up programme with employers availing of the EWSS who display high risk indictors. Where agreement cannot be reached on issues identified, Revenue will raise an EWSS assessment which can be appealed to the Tax Appeals Commission within 30 days. “Other reasonable basis” (page 34) Employers will be required to submit supporting documentation to demonstrate a severe disruption to normal operations due to the pandemic resulting in a material adverse impact to the financial performance of the trade.

That was one of the recommendations of the Institute in its letter to HM Treasury in response to its review of the effectiveness of the Office of Tax Simplification (“OTS”). The Institute also commended the formal and informal engagement it has had with the OTS over the last five years, including its current workstream which explores options to change the end of the tax year. The OTS itself published evidence last week in response to the HM Treasury review. Overall, the following key recommendations were made:- The UK Government should consider how it can widen the remit of the OTS in future, in the context of both development and implementation of tax policy, whilst maintaining its independent status; The UK Government needs to urgently develop and begin implementing a defined roadmap to tackle tax complexity in the UK, beginning with income tax first. The OTS can play a crucial role in supporting the UK Government during the course of this work; and In future, the UK Government needs to be more transparent, where it can be, in setting out what it is doing in response to the various reviews, workstreams and reports of the OTS. The OTS has also published Making better use of third party data: a vision for the future, a new report exploring ways to use third party data to make tax easier.

Aoife Lenox explains how a better understanding of temperament can help introverts acclimatise to office life. ‘We’ve been preparing for this our whole lives’ was a popular introvert working-from-home meme in March 2020. No commute and the convenience, at least in the short-term, worked for most people, but many extroverts found the disconnect from colleagues quite difficult. Introverts relished the opportunity to retreat from busy and overstimulating work environments, finding time to recharge during the day (albeit with home-schooling challenges), more emphasis on one-to-one communication, and the ability to contribute in meetings via chat functions. In this article, I will explain how your temperament influences how you work and, as an introvert, how you can successfully navigate a return to the office. Understanding temperament Psychologist Carl Jung developed the terms ‘introvert’ and ‘extrovert’ 100 years ago. He noticed that some people were more energised by an outward focus while others were more inward. Up to half of the population are introverted, but many of us use character traits to perform at work – being more vocal than we naturally are or showing more energy than we feel. This, I have found, leaves people confused about temperament. Influence on work Extroverts talk to think, and introverts think to talk. Introverts are internal processors and, as evidenced by MRIs of the introvert and extrovert brain, have increased activity in the pre-frontal cortex. This explains our inclination for deep thinking and reflection. It is why we can be slower to make decisions, need additional time to process, can be reluctant to speak up at meetings, and can get drained by excessive social interaction. Introverts’ increased sensitivity to dopamine, which can fuel and energise an extrovert, has the opposite effect on an introvert – often in the form of burnout from a full week in the office. Thrive A recent study by Aviva found that personality has such an impact on our wellbeing that it should be included in organisations’ wellbeing strategies. All change begins with awareness. To successfully navigate a return to the office, you might consider the following strategies: If you find your office environment overstimulating, speak to your others about your need to recharge. This might be a walk outside or time in a quiet room. I find closing my eyes for five minutes helpful. A hybrid or flexible working model also offers the opportunity to balance recharge time. Expressing our needs is important for mental wellbeing. If you need additional time to process information in a meeting, use questioning techniques to ensure that you can still contribute authentically. Identify and use your strengths to promote feelings of confidence and wellbeing. Unfortunately, negative stereotypes on introversion still pervade, so showcasing our strengths is very important. It is natural to feel anxious if you are returning to the office in the near future. Understanding your temperament allows you to recognise your needs and identify ways to create a work experience that works for you. If you are leading other people, have open conversations about their feelings on returning to the office. Remember: there is no ‘one size fits all’ solution. As the saying goes: we have all been through the same storm, but we have been in different boats. So let’s take it slow. Aoife Lenox, the founder of Inside Strategies, is an introvert strengths coach, trainer and people specialist. She runs webinars, workshops and offers people and culture support to SMEs.

The CCAB-I issued recommendations for Budget 2022 to all TDs and Senators of the Oireachtas on Friday.  Several important tax changes are recommended including a rewrite of tax law governing the eligibility of expenditure for the R&D tax credit, the reduction of the CGT and CAT tax rates, reform of the tax system to recognise the costs of remote working and the simplification of the capital allowance regime for energy efficient equipment.  The CCAB-I also urged TDs and Senators to make legislative provision for a temporary change to section 997A TCA 1997 in Finance (Covid-19 and Miscellaneous Provisions) Bill 2021 (Covid-19 2021 Bill), currently moving through the Dáil, to address the issue of proprietary directors not having entitlement to credit for PAYE warehoused by their employer.  If you or your clients are impacted by the interaction of section 997A and the Tax Debt Warehousing Scheme, you may wish to bring the matter to the attention of your local TD before the Covid-19 2021 Bill is passed into law in the next week or so.   The letter accompanying the submission to all TDs and Senators explains that proprietary directors of companies in the Tax Debt Warehousing scheme will not have a credit for PAYE warehoused by their employer company in the calculation of their income tax liability for 2020 and preliminary tax liability for 2021.  A temporary legislative measure is urgently required to ensure that directors of SMEs are not faced with a tax bill due to their employers’ participation in the Tax Debt Warehousing Scheme for PAYE purposes.  The Covid-19 Bill 2021 is expected to be passed into law before the Dáil summer recess of 14 July.  Therefore, immediate action is required to bring about a legislation amendment in time.  The CCAB-I’s Pre-Budget Submission 2022 also noted that moves to increase Employers PRSI will stifle job creation and certain tax measures should be considered to help developers manage the cost of building projects with the goal of increasing the supply of houses. 

The National Economic Dialogue is the principal forum for Ministers, representative bodies such as Chartered Accountants Ireland, employer representatives, trade unions and social campaigners to raise issues for consideration in October’s Budget. Attending the event Chartered Accountants Ireland representatives stressed that the key to rapid economic recovery lies in re-establishing high level quality employment which in turn will generate additional income tax and PRSI to fund the Exchequer as we rebuild our society and economy.  Member surveys indicate that as pension scheme auto-enrolment measures and statutory sick pay entitlements which rebalance supports between the public and private sector are broadly accepted, but the Institute emphasised that such supports come at a cost to private enterprise.   The Institute also noted that while Ireland’s economic outlook is positive, short-term uncertainty means that the continuation of wage supports and COVID-19 business supports is crucial.  The event this year included contributions from An Taoiseach Micheál Martin, Minister for Finance Paschal Donohoe, Minister for Public Expenditure and Reform Michael McGrath, Tánaiste and Minister for Enterprise Trade and Employment Leo Varadkar along with seven other Government Ministers.  An Taoiseach Micheál Martin noted that the current level of spending by the Government is not sustainable and must move to the next stage while also stating that housing is at the centre of our recovery. Minister for Finance Paschal Donohoe said that the State cannot continue to run an expansionary budgetary policy while economic growth accelerates. Minister for Public Expenditure and Reform Michael McGrath said that finances must be managed sensibly as we emerge from Covid to avoid major problems down the line. The Institute was represented at the event by Brian Keegan and Norah Collender of the Advocacy and Voice department.    

Difficult conversations arise in every facet of our lives whether it’s in romantic relationships, personal relationships with friends or family or within the workplace.  Even the thought of these types of conversations can stir up a whole host of feelings and emotions with many experiencing anxiety, nervousness or stress. However, if you approach these discussions in the right way, there is no need to fear them. Executive coach, corporate role player and actress, Jennifer O’Dea, provides unique insight on how to approach conversations that you would rather avoid. Her recent webinar centred on how best to protect and manage your emotional state when faced with such a daunting task. Here we outline Jennifer’s 5-point plan to successfully manage these challenging conversations and tackle the feelings they can evoke. Preparing Yourself Taking a few moments to physically and emotionally prepare will only benefit your execution and the outcomes of the conversation.   Physically, you can prepare by removing the pent-up energy in your body by simply standing up, stretching, moving away from your desk and identifying tension in the body. Do not underestimate the powerful, restorative and calming effect your breath can have. Not only does deep, belly breathing help slow down your heart rate, reduce the physical signs of anxiety and nervousness but it can also prep your voice for more authoritative and confident speech. Emotionally, check in with yourself before checking in with the other person! Are you prepared emotionally for this? Don’t dwell on the negative thoughts or feelings of dread, try to put yourself in a better frame of mind before engaging with the other person. Again, connect with your breath and focus on the task ahead. Difficult conversations or potential conflict can be overwhelming, stressful and bring on a flurry of emotions. Remember, you cannot control the arrival of emotions, but you can control the behaviour associated with that emotion and choose how you respond. Planning Plan for the conversation by mapping out how you will begin the conversation. What are you going to say? How are you going to say it?  The opening of the conversation can be the most difficult and rehearsing those first few lines can instil confidence to start off on the right foot. Ask yourself what the objectives and motivations of the conversation are.   Asking Powerful Questions Without questions and inviting the other party to be involved in the conversation, it can quite frankly turn into a monologue. By asking question, you can find out what is going on with the other party and help open up the conversation. Be aware and mindful of the language you use in your questions so you can elicit a two-way conversation. Ask open ended questions or ‘Wh’ questions that require a full response to gain insight and information from the other person.  Avoid asking multiple questions all at once. Using your Listening Skills While asking the right questions is key to facilitating the conversation, listening to the answers is equally important. Jennifer outlined 5 levels of listening; Ignoring (tuning out) Pretending (not listening to what the other party is actually saying) Selective (listening for validation or waiting for the opportunity to talk again) Attentive (listening but also observing other ques such as body language) Empathetic (understanding their point of view).   For a frank and open conversation, attentive and empathetic listening is the healthiest and most mature listening skill to hone in on. The Power of Silence The perfect partner to powerful questioning and listening is silence. Be comfortable in the uncomfortable silence. By creating this pause it can encourage the other person to speak, make them feel heard and can diffuse the tension and tone of the conversation.   Again, to facilitate a two-way discussion silence can take the pressure off to always lead and point the conversation and can allow it to go in a different direction at the will of the other party.  And there you have - tips on managing difficult conversations! To gain more in-depth insight into the topics mentioned above, you can access a recording of the webinar in full here. If you are encountering difficulties in life, please know CA Support offer a wide range of services including wellbeing coaching and career support.  You can contact the CA Support team in confidence on mobile: (353) 86 024 3294 or email: casupport@charteredaccountants.ie. CA Support relies on the generosity of the profession to provide such fundamental services and help members in need. If you would like to make a donation to our charity, please visit our donations page on how you can help.

The Finance (Covid-19 and Miscellaneous Provisions) Bill 2021 was published last week. The provisions contained in the Bill provide for enhancements to existing COVID-19 supports, as well as the introduction of the Business Resumption Support Scheme, as announced in the Economic Recovery Plan. The Bill also gives statutory effect to the Financial Resolution passed by the Dáil in relation to the rate of stamp duty applying on the bulk purchase of housing. The Bill amends the provisions contained in the Financial Resolution to ensure some unintended consequences are avoided. It is expected that the Bill will pass through the Dáil before the summer recess in mid-July.   Finance (Covid-19 and Miscellaneous Provisions) Bill 2021 Employment Wage Subsidy Scheme Section 2 of the Bill amends section 28B of the Emergency Measures in the Public Interest (Covid-19) (No.2) Act 2020 to provide for the: extension of the EWSS to 31 December 2021; retention of the current enhanced subsidy rates until 30 September 2021; retention of the 30% reduction in turnover or orders threshold; and widening of the reference period to assess eligibility for the scheme with effect from 1 July 2021. Covid Restrictions Support Scheme (CRSS) Sections 3 and 4 of the Bill amends section 484 and 485 TCA 1997 to provide for the extension of the specified period from 31 March 2021 to 30 September 2021. Section 4 amends section 485 TCA 2997 to provide for enhanced restart week payments, the level of which depends on the date the business reopens: where the “restart week” occurs between 29 April 2021 to 1 June 2021, the restart payment will be an amount equal to two weeks at double the normal rate of CRSS (subject to a maximum weekly amount of €5,000); where the “restart week” occurs between 2 June 2021 to 31 December 2021, the restart payment will be an amount equal to three weeks at double the normal rate of CRSS (subject to a maximum weekly amount of €10,000); and in all other cases, the standard restart week payment will apply, which is one week at the standard rates of CRSS (subject to a maximum weekly amount of €5,000). A business may qualify once for either the double restart week payment or triple restart week payment. Business Resumption Support Scheme (BRSS) Section 5 of the Bill provides for a new section, section 485A TCA 1997, which makes provision for the BRSS. Its key features are: The scheme is available to affected self-employed individuals and companies who carry on a trade or trading activities, the profits from which are chargeable to tax under Case I of Schedule D. It is also available to persons who carry on a trade in partnership, and any trading activity carried on by charities and sporting bodies. To qualify under the scheme, a business must be able to demonstrate that the turnover derived by the business during the defined specified period of 1 September 2020 to 31 August 2021 will be no more than 25% of the derived turnover when compared to a defined comparative reference period. Qualifying taxpayers will be able to make a claim for an amount equal to three times the amount as derived by 10% of their average weekly turnover during the reference period up to €20,000 and 5% thereafter, subject to a maximum payment amount of €15,000. Payments made under the scheme will be treated as an advance credit for trading expenses. For businesses established before 26 December 2019 the claim will be based on their actual average weekly turnover in the period commencing on 1 January 2019 or, if later, the date on which the person commenced its relevant business activity and ending on 31 December 2019. For businesses established on or after 26 December 2019, but before 10 March 2020, the claim will be based on their actual average weekly turnover in the period from the date that the relevant business activity commenced and ending on 15 March 2020. For businesses established on or after 10 March 2020, but before 26 August 2020, the claim will be based on their actual average weekly turnover derived during the period from the date that the relevant business activity commenced and ending on 31 August 2020. To make a claim under the scheme, a number of other conditions must be satisfied including that the person has an up-to-date tax clearance certificate, has complied with their VAT obligations, is not entitled to make a claim for the CRSS scheme in respect of any week that includes 1 September 2021 and that the business is actively carrying on its trade and has an intention to continue to do so. The person must register to claim on ROS and make a declaration that they satisfy the conditions to make a claim under this section. Provision is made for the publication of the name of claimants of BRSS on Revenue’s website. Reduced rate of VAT for the hospitality sector Section 6 of the Bill amends section 46 VATCA 2010 to extend the application of the 9% VAT rate on the supply of restaurant and catering services, guest and holiday accommodation and entertainment services such as admissions to cinemas, theatres, museums, fairgrounds, amusement park and sporting facilities, and also to hairdressing and the sale of certain printed matter such as brochures, maps and programmes until 31 August 2022. Tax Debt Warehousing EWSS Warehousing Section 7 of the Bill provides for the warehousing of EWSS overpayments received by employers. This scheme will have three periods: Period 1 (the “Covid-19 restricted trading phase”) – 1 July 2020 (the beginning of the “qualifying period” for EWSS) until 31 December 2021; Period 2 (the “zero interest phase”) – no interest will be chargeable on warehoused EWSS debts from Period 1 from 1 January 2022 until 31 December 2022; and Period 3 (the “reduced interest phase) – interest will be charged at 3% per annum on Period 1 warehoused EWSS debts from 1 January 2023. Where an employer fails to meet the conditions for debt warehousing the zero interest and reduced interest rates will no longer apply and the 8% rate will be re-imposed. Extension of the Debt Warehousing Scheme for TWSS, VAT, Employer PAYE liabilities, income tax balancing payment for 2019, preliminary tax 2020 and balancing payment for 2020 and preliminary tax for 2021 Sections 8, 9, 10, 11 and 12 of the Bill give effect to the extension of the Debt Warehousing Scheme announced as part of the Economic Recovery Plan. The amendments provide for: Period 1 (the “COVID-19 restricted trading period”), which was due to end on the last day of the taxable period next following the taxable period in which the recommencement date falls, to now end on 31 December 2021; Period 2 (the “zero interest period”) to being on 1 January 2022 and end on 31 December 2022; and Period 3 (the “reduced interest period”) to now begin on 1 January 2023 and end when the COVID-19 deferred liabilities are discharged in full. Stamp duty on acquisition of 10 or more residential properties Section 13 gives statutory effect to the Financial Resolution that passed on 19 May 2021. This section inserts section 31E in the SDCA 1999, which imposes stamp duty at a rate of 10 percent on acquisitions, on or after 20 May 2021, of certain residential properties (houses and duplexes but not apartments) where an aggregate of 10 or more units is acquired during a rolling 12-month period. Section 14 of the Bill introduces a provision that was not included in the Financial Resolution, and further amends the new section 31E SDCA 1999. Under the new provision, the acquisition of residential properties that are leased to the housing authority for certain social housing purposes is exempt from the new 10% rate. These are leases under the ‘Mortgage to Rent’ scheme, whereby properties that are surrendered to the financial institution holding the mortgage are sold to a private company in tandem with an agreement to then lease the property to a local authority, who in turn leases it to the existing occupants so that they can continue to live in the property. This exemption commences on the date of the passing of this Act.

Over the last number of years, ESG has become increasingly important to investors. By dedicating time and resources to ESG now, companies can reap greater rewards in the future. Edel O’Reilly explains. In my organisation, I act as a conduit between many publicly listed companies and the global investor community, and I have witnessed first-hand how important the issue of environmental, social, and governance (ESG) criteria has become to that community in recent years. Increased regulation, societal demand, underlying customer demand and perhaps, most importantly, improved investment outcomes are the key issues that have fuelled this change, and global investors and lenders now see the adoption of ESG practices as a crucial driver of value creation. This has been reflected in an acceleration in engagement levels between companies and their investors on the key issues.  What are investors looking for? So, what do investors care about and what are they looking for? I regularly organise corporate governance and ESG roadshows, and investors are intensely focused on corporate governance as a key indicator of evaluation. Why? Because good governance underpins strong business performance without excessive risk-taking. Investors focus their attention on board members, the processes in place to support adequate oversight, and board accountability. Board chair and members For allocators of capital, it is critical that the board chairperson is independent, while a diversity of skills and additional board experience are important criteria for board members. And, as the world becomes ever more digital, investors like to see board members who have cybersecurity and IT skills. Processes and oversight When it comes to governance architecture, best practice dictates that there should be three board committees: A nominations committee to ensure board balance; An audit committee to oversee the financial reporting aspects; and A remuneration committee with responsibility for proper alignment with executive pay. Investors want to see balanced compensation packages for management teams that reward performance but that are also related to long-term goals. Investors assess potential long-term value by judging the quality of policies and processes in place and the board’s diligence and care in overseeing their implementation. Accountability Critically, good governance can’t stand still and, as a company grows, it should have governance in place for each stage of its maturity. There must be continual reviews of whether the board structure and policies in place are fit for purpose at every stage of development and growth phase of the company. A formal external evaluation process and response plans to any gaps identified are important steps and initiatives that investors like to see.  Companies that demonstrate a strong commitment to ESG best practices will benefit from greater access to debt and equity capital at competitive costs. Any company seeking a loan or equity investment will potentially be screened through an ESG lens, which will determine access to – and the cost of – such capital. So, the drive for good corporate governance has never been more important.  Investors are rewarding companies that can prove they are legitimately committing resources to sustainable goals – good governance is an essential part of this journey.  Edel O’Reilly is Head of Investor Relations at Goodbody and a member of the Chartered Accountants Ireland Sustainability Expert Working Group.

The Northern Ireland Protocol represents a major strategic advantage for businesses which locate in Northern Ireland, Chartered Accountants Ireland has said today. The accountancy body which represents almost 25,000 members across the island of Ireland, has highlighted the significant positive feedback it has received from businesses regarding the unique market access into both Great Britain and the EU that they enjoy.   The Institute has sounded a note of caution however, highlighting the focus to date in discourse around the Protocol on the consumption economy, at the risk of missing out on the significant production opportunities that it can afford Northern Ireland’s economy.   The comments come as Chartered Accountants Ireland launches a guide “Building on Opportunity – A Guide to Foreign Direct Investment in Northern Ireland” showcasing Northern Ireland as a world-class location in which to do business.  Commenting, Cróna Clohisey, Public Policy Lead with Chartered Accountants Ireland said “While the Protocol itself remains a topic of heated debate at political level, it is clear to us from our engagement with the business community, that many businesses are already reaping the benefits that Northern Ireland’s unique position affords them.  “Post-Brexit, trade in goods has continued largely as it did before the UK’s departure from the EU with no customs duties or customs paperwork on the sale of goods to both Great Britain and the EU (including Ireland) from Northern Ireland. This unique market access, in addition to a skilled workforce and business friendly environment makes Northern Ireland an attractive base for companies, particularly in the manufacturing and distribution sectors, that want to trade in both the UK and EU markets.” Foreign direct investment has remained strong, with 6,000 more companies now operating in Northern Ireland than in 2016. Northern Ireland is now home to more than 1,100 international companies, employing 100,000 people. Clohisey continued, “The discourse has to date been overshadowed by a focus on the consumption economy, on bringing goods into the country. I think there is a real danger that this persisting, negative focus on the Protocol could lead to the greatest risk of all – missing out on the significant production opportunities that it can afford Northern Ireland.   “Those already located in Northern Ireland know its advantages as a place to do business – location; educated workforce; a stable and competitive tax system. But it is critical to highlight its ability to innovate and change with the times. Far from the ship building days of the past, the country has established itself in some of the world’s fastest growing and innovative industries including data analytics, cyber security, life and health sciences, clean energy, and aerospace.”   Over the next ten years, Northern Ireland will see over £1 billion of investment from the NI Executive and UK Government into four City & Growth Deals. This will further enhance the region as a significant destination for innovation and facilitate investment opportunities that further build upon Northern Ireland’s reputation in manufacturing, life sciences and artificial intelligence industries.   The Building on Opportunity guide can be downloaded here

While the Common Travel Area between Ireland and the UK has been preserved post-Brexit, businesses still need to be compliant when it comes to work and travel permission requirements for employees, says Doone O'Doherty. Now that the UK has officially left the EU, many employers have started to see travel and work restrictions apply to certain employees who, before Brexit, could have travelled and worked freely within the EU. Employers need to ensure compliance for their employees and indeed for their own organisations. Ireland is in a somewhat unique position insofar as the free movement of UK and Irish nationals between both countries has been retained under the Common Travel Area agreement. There may be an assumption that Brexit really has no immediate impact on the people agenda for Irish employers and, for many organisations, this is the case. For others, however, particularly those with UK or EU national employees, Brexit throws up a completely new conundrum, with concerns over immigration and global mobility becoming something that employers may need to navigate, often for the first time.  Work permission required   The bottom line is that, since 1 January, freedom of movement of UK and EU nationals between the UK and the rest of the EU has ended. If you have either UK national employees who need to travel to another EU member state, or EU national employees who need to travel to the UK, these individuals are now subject to potential work permission requirements. There may also be restrictions and time limits on the activities they can carry out as business travellers. Where once a UK national could simply move to another EU member state at short notice, and vice versa, attention and planning now need to be given to such travel arrangements. Not only does consideration need to be given to any new movement of people, EU nationals already resident in the UK will have needed to secure their right to live in the UK under the EU Settlement Scheme. Similarly, UK nationals resident in the EU will need to secure their status and regularise their position under the specific rules for that country. Thorough review needed  Businesses need to undertake a thorough review of their workforce and identify any frequent business travellers or those who are likely to be affected by immigration restrictions. This includes building potential immigration requirements and robust pre-travel processes into their Global Mobility Policies. Communicating with employees is also important to make them aware of any new pre-travel requirements or steps to secure settlement that they may need to undertake. Consider the potential cost impact of obtaining necessary immigration clearance. There are two aspects to consider: social security and the application of Irish PAYE rules to short-term business travellers. Social security  The Social Welfare Order 2020 came into effect on 1 January 2021. Its purpose is to ensure that the social security rights and entitlements of Irish and UK citizens under the Common Travel Area arrangements are maintained post-Brexit and that social security need only be paid in one jurisdiction. One key aspect is that it applies to Irish or UK citizens only, who may work in either one or both territories. Thankfully, supplementary provisions were included in a new protocol to the Trade and Cooperation Agreement on Social Security Coordination to ensure that EU or UK citizens who move between Member States will continue to be liable to pay social security contributions in one State at a time. Special provision is made for ‘commuters’, which provides that such individuals may be retained within their home country social security system. This is particularly welcome in the case of EU citizens living in the UK who commute or are posted to Ireland to work and who would not have been able to avail of the Social Security provisions above. Employers need to understand where their people work, their citizenship status and how to make the appropriate applications under the revised rules to the relevant social security authority. Irish PAYE and short-term business travellers  There is no change to the underlying tax rules in Ireland because of Brexit. However, there is likely to be increased short-term business travel between Ireland and the UK, largely due to our geographic proximity and the fact Ireland is the only English-speaking member of the EU.   One myth that often exists is the belief that, provided an individual spends less than 183 days in Ireland, there are no tax implications for their UK employer. This is far from the truth – Ireland has a comprehensive set of rules applicable to short-term business travellers/visitors (STBV) that can easily give rise to an obligation to operate Irish PAYE based on an individuals’ Irish workdays. Equally, it is possible to avail of some concessions in respect of STBVs whereby Irish PAYE does not need to be applied, but only if the appropriate due diligence is undertaken.  UK employers need to understand the travel patterns of their staff, the nature of the duties they are undertaking and the intended duration of those activities. Advice should be sought regarding the potential Irish PAYE (payroll withholding obligations) and whether there is a way to mitigate that obligation. Furthermore, the employer should implement a robust system of tracking an employee’s Irish workdays in order to mitigate any potential breaches. Doone O'Doherty is a Partner in People & Organisation at PwC.

Whist our Christmas event has been cancelled this year, charities are needing more and more support now more than ever.  We are partnering with New Horizon Youth Centre in Kings Cross, who provide a vital support network for 16-24 year olds with nowhere else to go. Through the ‘one stop shop’ services provided at the daycentre, via outreach and remotely, supports thousands of young people experiencing homelessness in London to improve their wellbeing, change their economic circumstances and find somewhere that they can call home.  In place of your usual Christmas celebrations: We have outlined suggested donations below but every little helps! £50  A gift of £50 would help give a young person experiencing homelessness a Christmas filled with food and small gifts. £100  A gift of £100 could help buy basic essentials, such as sleeping bags, toiletries and winter clothes, that young people experiencing homelessness desperately need. £1,000  A gift of £1,000 would provide an hour of counselling to over 50 young people. Whilst these are only suggestions, any donation you can make will be greatly appreciated, so please make a difference by donating here and please do share this link with friends, family and colleagues. Thank You

With international tax reform progressing at unprecedented speed, Susan Kilty explains why Irish businesses must continue to participate actively in the discussion. With all the global uncertainty that Ireland is facing due to COVID-19 and Brexit, there is a risk that the OECD global tax reforms – the other major threat to Irish business and the economy – will be pushed further down the corporate agenda. But to do so would be very risky. Ireland must engage with this process now, at both the political and corporate level. The world of international tax is in a state of extreme flux as governments grapple with changes in the way multinationals do business. It is worth reiterating that Ireland has attracted healthy levels of foreign direct investment (FDI) over the past 30 years, and the multinational community has contributed significantly to our economic success. According to the OECD, Ireland received more foreign direct investment in the first half of this year than any other country. Along with Ireland’s near-iconic 12.5% tax rate, a crucial element in our continuing ability to attract international investment is the stability and transparency of the corporate tax regime here. Investors from abroad who establish activities in Ireland tend to be quite sensitive to changes in the taxation system. They like certainty and stability in a tax code, which is why Ireland presents such an attractive proposition. Ireland cannot afford to lose FDI as a result of turbulence in the global tax landscape at this time. As corporation tax accounts for almost 18% of Ireland’s total tax take, any change to the regime threatens to seriously undermine the attractiveness of our FDI model and negatively impact our revenue-raising ability. The crux of the matter is that we, and many other countries, apply 20th century tax systems to 21st century e-commerce business models. Businesses have an increasingly digital presence, and many no longer trade out of brick and mortar locations. This is not limited to so-called technology companies, but can be seen across industries and in businesses of all sizes. Businesses sell freely across borders without ever needing to set up operations abroad. This new digital way of trading is not always captured in our analogue tax rules, and the rules must be realigned with the reality of modern e-commerce. However, to tax a multinational business, you need a multinational set of rules. This is where the OECD comes in, but the uncertain shape that the new rules might take brings more uncertainty for businesses at a time when it is least needed. Many clients cite the changing international tax environment as one of the top threats to potential revenue growth. And although countries now face enormous bills for COVID-19, one sure thing is that BEPS, OECD and tax reform will not go away. International corporate tax reform is happening, and it will impact many businesses and our economy. Companies need to stay on top of these changes and prioritise the issues that will affect them. OECD proposals The OECD proposals offer a two-pillar solution: one pillar to re-allocate taxing rights and ensure that profits are recorded where sales take place, and a second pillar to ensure that a minimum tax rate is paid. At the time of writing, a public consultation is open for stakeholders to share their views with the OECD on the proposals that were recently summarised by way of two “blueprint” documents, one for each pillar. Pillar One seeks to give market jurisdictions increased taxing rights (and, therefore, increased taxable income and revenues). It aims to attribute a portion of the profits of certain multinational groups to the jurisdictions in which their customers are based. It does this by introducing a new formulaic allocation mechanism for profits while ensuring that limited risk distributors take a fair share of profits. Several questions remain as to how the Pillar One proposals, which constitute a significant change from the current rules, will be applied. Pillar Two, on the other hand, seeks to impose a floor for minimum tax rates across the globe. This proposal is very complicated. It is much more than a case of setting a minimum rate of tax. It is made up partially of a system that requires shareholders of companies that pay low or no tax to “tax back” the profits to ensure that they are subject to a minimum rate. At the same time, rules will apply to ensure that payments made to related parties in low-tax-paying or no-tax-paying countries are subject to a withholding tax. Finally, it can alter the application of double tax treaty relief for companies in low-tax-paying or no-tax-paying countries. Agreeing on the application and implementation of this pillar will be incredibly difficult from a global consensus point of view. Several supposed “safety nets” in Pillar Two are also likely to be of limited application. For example, assuming that the minimum tax rate is set at 12.5%, this does not mean that businesses subject to tax in Ireland will escape further tax. Similarly, assuming that the US GILTI (global intangible low-taxed income) rules are grandfathered in the OECD’s proposal, this does not mean that the US GILTI tax applies as a tax-in-kind tax for Pillar Two purposes. Pillar Two poses a significant threat to Ireland, as it reduces the competitiveness of our 12.5% rate to attract FDI and, coupled with the Pillar One profit re-allocations, could reduce our corporate tax take. The OECD estimates that once one or both of the pillars are introduced, companies will pay more tax overall at a global level, but where this tax falls is up for negotiation – and this is why early engagement by all stakeholders is critical. While the new proposals will undoubtedly have an impact, it is not certain that Ireland’s corporation tax receipts will fall off a cliff. Ireland has already gained significantly in terms of investment from the first phase of OECD tax reform, and this has helped to drive a significant increase in corporate tax revenue. But the risks must nevertheless be addressed. There is, of course, the risk that the redistribution of tax under the rules directly under Pillar One and indirectly via Pillar Two will impact our corporate tax take. But even if the rules have no impact on a company’s tax bill, they could still impose a considerable burden from an administrative perspective, and the complexity of the rules cannot be overestimated. At a time when businesses are grappling with other tax changes, led by the EU and domestic policy changes, this would be a substantial additional burden on the business community. The OECD is progressing the rules at unprecedented speed in terms of international tax reform. The momentum behind the process comes from a political desire for a fair tax system that works for modern business. However, does this rapidity risk the international political process marching ahead of the technical tax work? This is where Ireland, both government and corporate, needs to play a vital role. While the consultation period on both pillars is open, the focus for stakeholders should be on consulting with the OECD on the technical elements of its plan. Considering the OECD’s stated objective to have a political consensus by mid-2021, this could be one of the last opportunities for stakeholders to have a say in writing the rules. The interplay between the OECD and the US Treasury cannot be ignored when considering the OECD’s ability to get the proposals over the line. The US Treasury decided to step away from the consultation process with the OECD for a period in mid-2020. This, of course, raised questions around whether the OECD proposals could generate a solution that countries would be willing to implement. Added to this, the OECD has always positioned Pillar One and Pillar Two as an overall package of measures and has stressed that one pillar would not be able to move forward without the other. The “nothing is decided until everything is decided” basis of moving forward is a risky move, but the OECD recently rowed back on this stance. If the OECD fails to reach a political consensus by 2021, we could very well see the EU act ‘en bloc’ to introduce a tax on companies with “digital” activities. This could result in differing rules within, and outside of, the EU. It would also increase global trade tensions, all of which would not be good for our competitiveness. As a small open economy, Ireland will always be susceptible to any barriers to global trade. A multilateral deal brokered by the OECD therefore remains the best option – the last thing we want to see is the EU accelerating its own tax reform or, worse still, countries taking unilateral action. For the Irish Government, providing certainty where possible about the future direction of tax is critical. Where we have a lead is in how we provide that stability and guidance where we can. The upcoming Corporate Tax Roadmap from the Department of Finance will be an opportunity to give assurances in these uncertain times. Next steps for business The public consultation will be critical for businesses to have their say in shaping the rules. Ireland Inc. must continue to engage constructively with the OECD to try to shape the outcome so that we maintain a corporate tax system that is fit for purpose, is at the forefront of global standards, and works for businesses located here. Doing so would ensure that we articulate the position of small open economies like our own. Each impacted business must take the opportunity to comment on the proposals, as this may be the last chance to have a say. Indeed, what comes out of the consultation period may be the architecture of the rules for the future. We know that difficult decisions must be made at home and abroad in terms of the new tax landscape, and made with additional pressures we could not have foreseen 12 months ago. Although it may seem that much is out of our control, Irish businesses must continue to participate actively in the discussions and ensure that their concerns are heard. The game may be in the final quarter, but the ball is in our hands. Susan Kilty is a Partner at PwC Ireland and leads the firm’s tax practice. Point of view: Fergal O'Brien Since the start of the BEPS process in 2013, Irish business has recognised the importance of the work to our business model and the country’s future prosperity. At its core, BEPS has seen a further alignment of business substance and tax structures at a global level. This has resulted in an often under-appreciated surge in business investment, quality job creation and, ultimately, higher tax revenue for the Irish State. With its strong history as a successful location for foreign direct investment, and substance in world-class manufacturing and international services, Ireland was well-placed to benefit from the new global order. The boom in business investment, which last year reached over €3 billion every week, and increase in the corporate tax yield from €4 billion in 2013 to €11 billion in 2019, are evidence of the further embedding of business substance in the Irish economy. The current round of BEPS negotiations will have further significant implications for the Irish economy, and particularly for the rapidly growing digital economy. Ibec is working directly with the OECD to ensure that any further changes to corporation tax recognise the central role of business substance and locations of real value creation. Fergal O’Brien is Director of Policy and Public Affairs at Ibec.  Point of view: Norah Collender The OECD’s proposals to address the challenges of the digitalised economy will have a disproportionate negative impact on small, open exporter economies like Ireland. Earlier consultation papers issued by the OECD on taxing the digitalised economy suggested that smaller economies could benefit from international tax reform emanating from the OECD. However, the OECD now openly admits that bigger countries stand to benefit from its proposals more than smaller countries, and the carrot has turned into the stick in terms of what will happen if smaller countries do not support the OECD. Ireland is acutely aware of the dangers ahead if countries take unilateral action to achieve their vision of international tax reform. But that does not mean that countries like Ireland should be rushed into accepting international tax rules that fundamentally hamstring Irish taxing rights. Genuine consensus must be reached to ensure that international tax reform is sustainable in the long-term. Likewise, the new tax rules must be manageable from the multinational’s perspective and from the perspective of the tax authority tasked with administrating the rules. A rushed outcome to the important work of the OECD will make for tax laws that participating countries, tax authorities, and the all-important taxpayer may not be able to withstand in the long-term. Norah Collender is Professional Tax Leader at Chartered Accountants Ireland. Point of view: Seamus Coffey How Pillar One and Pillar Two of the OECD BEPS Project will ultimately impact Ireland is uncertain. One sure thing, however, is that there will be changes to tax payments. This will be a combination of a change in the location of where taxes are paid and perhaps also an increase in tax payments in some instances. But there will likely be both winners and losers. From an Irish perspective, there might have been some comfort in that the loser could have been the residual claimant – the country at the end of the chain that gets to claim taxing rights on the profits left after other countries have made their claim. As US companies are the largest source of Irish corporation tax revenue, it might have been felt that most of the losses would fall on the US. However, significant amounts of intellectual property have been on-shored here. Ireland, therefore, has become a residual claimant for the taxing rights to some of the profits of these companies. At present, Ireland is not collecting significant taxes from these profits as capital allowances are claimed. If BEPS results in a significant reallocation of these profits, we might never collect much tax on them. Seamus Coffey is a lecturer in the Department of Economics in University College Cork and former Chair of the Irish Fiscal Advisory Council.

A slide summarising execution tips from the London Society's recent 'Negotiating with Rigour' webinar with Mark Gough and Ben Francis of PwC is available to view...