HM Treasury in the UK has issued a consultation response on improving the effectiveness of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs). The response contains a summary of the UK Government’s feedback and next steps setting out the areas where it intends to make changes to the MLRs. The areas where there will be change are listed in the response and reproduced below. • Enhanced due diligence on complex transactions • Enhanced due diligence on high-risk third countries • Due diligence on pooled client accounts • Due diligence triggers for certain non-financial firms • Onboarding of customers in bank insolvency scenarios • Information sharing between supervisors and other public bodies • Supervisor cooperation with Companies House • Currency thresholds currently in euros • Regulation of sale of ‘off-the-shelf’ companies by Trust and Company Service Providers • Registration and change in control for cryptoasset service providers • Registration requirements for the Trust Registration Service In addition, improvements in sectoral guidance in some areas will be sought and  HM Treasury and the Department for Science, Innovation and Technology will jointly produce guidance on using digital identities for MLRs identity verification checks. The response states the intention to publish a draft Statutory Instrument in the coming months for technical feedback, before laying in Parliament later this year time permitting. Readers can access the consultation response on MLRs here. This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.

In a Press Release launching their Transformation Roadmap, HMRC singled out for special mention a new online service for all PAYE taxpayers, which will make it simpler and easier to check and update their income, allowances, reliefs and expenses in future. This will be available via the Personal Tax Account or through the HMRC app. For a number of years, Chartered Accountants Ireland has been calling for a system like this, similar to the one already available for employees in Ireland via myAccount on ROS. The Exchequer Secretary to the Treasury laid a Written Ministerial Statement on the roadmap. The roadmap sets out a wide range of new services which will be developed, including new services for agents, something which the Institute has been consistently lobbying for, for several years. Ultimately, HMRC’s ambition is to develop a tax administration where 90 percent of taxpayer interactions will be digital by 2030. As set out at the Spending Review last month, HMRC also has the objective of reducing the number of letters it sends by 75 percent by the same date. The roadmap therefore sets out in detail how HMRC plans to achieve these ambitious targets. The Institute has previously met with HMRC to discuss these targets, and met again last week to discuss the Transformation Roadmap[LD1] , with particular focus on the level of agent services which will be developed. Once again it would appear that a gap will start to widen between these and taxpayer services, which will be vastly improved, if the plan is implemented as intended. At the meeting, the group acknowledged the roadmap for its ambition and noted that the sound drafting. One important aspect that needs to be clarified over time will be timelines for implementation of the targets. HMRC noted that they plan on update the roadmap annually as the measures develop. An executive summary of the roadmap is also available.

We highlighted in Tax News on 14 July that the HMRC webinar on Making Tax Digital (MTD) for income tax which will take place on Tuesday 16 September from 1-2pm is open for booking. This webinar will be led by Sam Wood BSc ACA. Sam works with agents within HMRC’s Making Tax Digital programme and has a background in accounting and digital transformation. He is responsible for Cross Cutting Stakeholder Engagement, Policy and Strategy at HMRC and is a Chartered Accountant and a member of ICAEW with wide experience of Making Tax Digital from its inception. The Institute is also running a more detailed two-hour webinar, delivered by Tim Palmer, on Thursday 11 September which is also open for booking.

As covered in Tax News on 14 July, the second, and final, 2024/25 self-assessment payment on account for income tax and Class 4 National Insurance Contributions (NICs) is due for payment on or before midnight on Thursday 31 July 2025. Each payment on account is half of the previous year’s tax bill. Anyone who is self-employed is required to make two payments on account for 2024/25 unless: Their 2023/24 Self-Assessment tax bill was less than £1,000, or More than 80 percent of all the tax owed in 2023/24 was deducted at source, for example via PAYE. If a taxpayer knows that their tax bill for 2024/25 is going to be lower than that in 2023/24, a claim can be made to HMRC to reduce payments on account. Each payment on account made should be 50 percent of the person’s total income tax and Class 4 NICs liability for 2023/24. If the final tax liability in 2024/25 is greater than the total payments on account made, a balancing payment will be due on or before 31 January 2026.

Last week the Government also announced three technical consultations on draft legislation. More details are set out below. Raising standards project Following the package of measures announced at the Autumn 2024 Budget, on L-day HMRC also published two separate technical consultations, together with draft legislation. Overall, the measures are designed “to deter harmful practices, hold advisers accountable, and promote a more transparent and trusted tax advice market” and have the objective of supporting the Government’s three main priorities: to close the tax gap, enhance services, and modernise the tax system.   Both these consultations will run for eight weeks and will close on Monday 15 September. More details of the key proposals are set out below. Modernising and mandating tax adviser registration This consultation seeks views on the introduction of mandatory registration for tax advisers engaging with HMRC on behalf of clients, to ensure they meet minimum standards. Registration will be required from April 2026 and is supported by a £36 million investment in modernising HMRC’s adviser registration services. Enhancing HMRC’s powers and sanctions against tax adviser facilitated non-compliance This consultation seeks views on further measures to ‘support compliance and transparency in the tax advice market’. Proposals include strengthening HMRC’s powers to: Access information from advisers suspected of facilitating non-compliance, Apply proportionate penalties where there is evidence of such behaviour, and Publish details of advisers subject to HMRC sanctions.   HMRC also published a summary of responses on this measure, in response to the recent consultation in this space. Views on the draft legislative clauses and the practical implications of the proposed measures are sought by email to raisingstandardsconsultation@hmrc.gov.uk. Making Tax Digital (MTD) and Penalty Reform – draft legislation for technical consultation Last week, the Government also published draft legislation for Making Tax Digital for income tax and penalty reform. This aims to refine and simplify the existing framework and legislates for the changes announced in March at the Spring Statement. This includes: A deferral from MTD until at least 2029 for some groups, such as Ministers of Religion, Lloyds Underwriters, and recipients of the blind person’s allowance, Exemptions from MTD for others, including individuals with power of attorney, and non-UK resident entertainers with no other qualifying income, Technical and policy amendments, including the authority for HMRC to cancel or reset late submission penalty points and cancel associated financial penalties, A requirement for MTD users to submit their end of year tax return using MTD-compatible software, and A new qualifying income threshold for MTD for Income Tax of £20,000 to apply from 2028/29. As also mentioned at the Spring Statement, individuals will not be required to use MTD until April 2027 if they have information that they would need to submit using the SA109 supplementary pages. HMRC will work with stakeholders to finalise this deferral, which will be included in legislation later this year. In line with the existing tax policy framework, the aim of this technical consultation is to seek views on whether the draft legislation works as intended. To provide comments, please email: makingtaxdigitalconsultations@hmrc.gov.uk by 16 September 2025.

It was a busy day last Monday when the Government’s now traditional L-day kicked off with the publication of HMRC’s Transformation Roadmap (more on this later), the publication of several new technical consultations in three areas (see separate story), in addition to draft clauses for the next Finance Bill, covering a range of previously announced policy changes, including the controversial changes to inheritance tax. The key areas of draft legislation covered in the Bill are as follows: Private Intermittent Securities and Capital Exchange System (PISCES) tax implications, Income Tax: changes to Employee Car Ownership Schemes, Multinational Top-up Tax and Domestic Top-up Tax further amendments, Umbrella Companies: tackling non-compliance in the umbrella company market, Reform of the tax treatment of carried interest, Tax implications for companies and employees in relation to employees trading their shares on PISCES, Offshore Anti-Avoidance legislation, Changes to charity compliance measures, Better use of new and improved third-party data, and Reforming Inheritance Tax — unused pension funds and death benefits.

As we predicted last Monday, following HM Treasury’s response to the Institute’s letter on this issue, on L-day the Government published draft finance bill clauses which confirm that the changes to Agricultural Property Relief and Business Property Relief will be proceeding as planned from April 2026. In the draft legislation as it currently stands, none of the recommended mitigations proposed by the Institute have been included. Read the Institute’s Press Release reacting to this in which we are seeking a special derogation from these changes for Northern Ireland, given the disproportionate impact of this in the region on the agricultural sector and family-owned businesses. The relevant Policy Papers on these reforms are also available here and here. The Institute is currently considering what further action is needed on this important issue and is also aiming to discuss this with local government. A full report on the other key announcements from L-day is covered later in this edition of Chartered Accountants Tax News. In the meantime, it is noteworthy that buried amongst the L-day publications is welcome confirmation that the Government has shelved Making Tax Digital for corporation tax.

On the 17 July 2025 the 2025 National Risk Assessment was published.  It is the fourth comprehensive assessment of money laundering and terrorist financing risk in the UK. It is the UK's stock-take of the collective knowledge of money laundering and terrorist financing risks and builds on the understanding of the risks identified in the 2015, 2017 and 2020 NRAs. Member firms are advised to review the assessment carefully and to update their AML risk assessments and policies and procedures accordingly.

Cróna Clohisey, Director of Members and Advocacy, Chartered Accountants Ireland said “Today’s revised National Development Plan (NDP) is a strong statement of intent towards securing Ireland’s competitiveness in the coming decade. It is encouraging to see such significant emphasis on addressing housing over the next five years. 1 in 4 SMEs surveyed by Chartered Accountants Ireland in April reported that their business has lost employees or seen prospective employees unable to take a role due to the unavailability of affordable housing. “Housing is only one element of the puzzle, however. We know the critical levers to delivery also include energy and water, so these significant deficits in the State’s infrastructure need to be addressed holistically if Ireland is to fully realise its ambition of becoming a place where businesses can thrive. Today’s announcements are a step in the right direction. “Another of the most frequent barriers encountered by our 40,000 members is access to childcare. Despite featuring as a key commitment in the Programme for Government, the revised NDP lacks detail on how more childcare places will be created for working parents. Greater priority must be given to an issue that so fundamentally affects the labour market. “As an all-island body, the Institute also welcomes the focus in the NDP on the Shared Island Fund, and we look forward to engaging with stakeholders on how the NDP will deliver cross-border infrastructure projects.”

Chartered Accountants Ireland has introduced an Annual Return for those firms supervised for AML purposes pursuant to the Anti-Money Laundering Supervision Regulations - TCSPs and Bookkeepers (The Regulations). The Regulations provide for the Institute’s AML supervision of trust and company service providers (TCSPs) and bookkeepers which fall within the Institute’s supervisory remit under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 as amended (the Act) and related agreements. These are entities which: are TCSPs and/or bookkeepers; and include Institute members amongst the entity's principals; and are not subject to the Public Practice Regulations since they do not provide any services which would meet the definition of public practice in the Public Practice Regulations; and are not subject to AML supervision by another competent authority pursuant to agreements between the Institute and other competent authorities as provided for by the Act. The annual return should be submitted by 31 August 2025. Queries should be directed to Professional Standards. Further information on the registration and supervision of members for AML purposes can be found on our authorisations page of our website.

Northern Ireland should be excluded from UK Government proposals to restrict the benefit of two key Inheritance Tax reliefs; agricultural property relief and business property relief, because of the disproportionate impact this is already having on the region’s agricultural sector and family-owned businesses. Chartered Accountants Ireland, the largest professional body on the island of Ireland, which represents over 5,000 members in Northern Ireland reiterated its position after the Government published draft legislation for the next Finance Bill. As announced last October, from April 2026, 100% relief will be limited to the first £1 million of combined agricultural and business property, with any value above this receiving relief at 50%, effectively resulting in an inheritance tax liability of 20%. Director of Members and Advocacy at Chartered Accountants Ireland, Cróna Clohisey said: “Yesterday on ‘L-day’, the Government published the draft Finance Bill clauses for this policy change which confirms, disappointingly, that they will commence from April 2026 as planned. On behalf of members, this Institute has engaged extensively with Government to emphasise the impact this will have in Northern Ireland. Farming is the biggest industry in NI, and farms and family-owned businesses are the heartbeat of our economy. “We recognise that in the current geopolitical and economic environment, difficult decisions are necessary, however, we feel that the impact of these changes has not been fully considered on a regional basis and will hit Northern Ireland harder. It is already causing forced, premature business sales and the loss of jobs, lives and livelihoods. Although we have some of the highest land prices in the UK, what the government has failed to grasp is that land values here do not correlate to the income generated. Any value is tied up in land and assets, not cash.” Data from the NI Assembly already suggests that by 2026 these changes will affect approximately 75 percent of dairy farms in Northern Ireland, which account for 60 percent of owned land and provide the majority of food production in NI. Clohisey continued: “Ultimately the Government is taking a broad-brush approach to address specific concerns that ‘non-farmers’ are investing in land to avoid inheritance tax. As a result, they are missing the opportunity to reframe this policy and include a range of mitigations to protect genuine farming activity and family-owned businesses.” Chartered Accountants Ireland is urging the Government to find a way to introduce a carve out for agricultural and family-owned business sectors in Northern Ireland. If there is not a willingness to do so, the Institute is calling on the Government to amend the draft legislation to include a range of mitigations. This would enable the Government to target this policy more effectively and reduce its negative impact before the legislation begins its journey through Parliament after the summer recess. ENDS

IAASA has issued a public consultation on their draft work programme for the period 2026 – 2028. Please see the consultation and draft work programme . The due date is no later than 5pm on 22 August 2025.

In this week’s post EU exit corner, we bring you the latest guidance updates and publications relevant in the post EU exit environment. The most recent Trader Support Service bulletin is also available as is the most recently published Brexit and Beyond newsletter from the Northern Ireland Assembly EU Affairs team. Miscellaneous guidance updates and publications This week’s miscellaneous guidance updates and publications are as follows: External temporary storage facilities codes for Data Element 5/23 of the Customs Declaration Service, Short shipments at temporary storage locations, Additional Information (AI) Statement Codes for Data Element 2/2 of the Customs Declaration Service (CDS), Submitting an electronic administrative document or an electronic simplified administrative document for excise goods, The Customs (Miscellaneous Amendments) Regulations 2025, Report a problem using the Customs Declaration Service, Make an entry summary declaration using the Import Control System 2, Apply for authorisation for the UK Internal Market Scheme if you bring goods into Northern Ireland, Categorising goods for Internal Market Movements from Great Britain to Northern Ireland, and Declare your goods to authorised use and completing authorised use.

In this week’s detailed miscellaneous updates which you can read more about below, the UK has laid further regulations on the Pillar Two rules which take effect from 24 July 2025 and HMRC is working on a new online form which will allow employers to report disputes on their pay as you earn (PAYE) liabilities. In other news this week: The latest Agent Update: Issue 133 is available; this sets out more information on a range of areas, including the ongoing Class 2 National Insurance Contributions issue which we reported on a few weeks back in miscellaneous updates. HMRC has also asked to share a separate update on this which contains supplementary information, HMRC is holding a webinar later this week on reporting via PAYE real time and how to provide accurate information - book onto the webinar now, The Public Accounts Committee has published a report on collecting tax from wealthy individuals that calls for further action and clarity from HMRC, The National Audit Office has published HMRC’s 2024/25 accounts, and The latest tax publications from the Institute for Fiscal Studies have been published: https://ifs.org.uk/articles/wealth-tax-would-be-poor-substitute-properly-taxing-sources-and-uses-wealth and https://ifs.org.uk/publications/taxing-capital-income-and-wealth-low-and-middle-income-countries-practice-principles. New Pillar Two regulations The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) (Amendment) Regulations 2025 have now been laid, and come into force later this week on 24 July 2025. The regulations enable HMRC to specify additions to the list of Pillar Two territories, qualifying domestic top-up taxes, and accredited qualifying domestic top-up taxes to take effect from a date before the notice is published. According to HMRC, this is a procedural change to ensure the effective date of changes in the UK aligns with the date in the central record of internationally agreed qualifying territories and taxes published by the OECD/G20 Inclusive Framework. It also means that there will be no requirement for individual Statutory Instruments which would otherwise be required due to the retrospective nature of such changes. Employer PAYE liability disputes HMRC is currently developing an online form which will enable employers to report disputes on their pay as you earn (PAYE) liabilities. Currently, employers can either call the Employer Helpline on 0300 200 3200, or write to HMRC at the following address: PT Operations North East England, HM Revenue and Customs, BX9 1BX, United Kingdom. Further information will be provided in due course.

The 2025 Administrative Burdens Advisory Board (ABAB) ‘Tell ABAB’ survey is open for completion. The ABAB survey is your opportunity to provide ABAB with insights on the tax system. The ABAB challenges HMRC on its performance, and aims to provide robust scrutiny of key initiatives, such as Making Tax Digital, and HMRC service standards. The ABAB also aims to provide crucial insight on the big issues faced by small businesses, including tax agents, in the tax system. Members are encouraged to complete the survey. The survey will take roughly 15 minutes to complete, and will remain open until 31‌‌‌ July 2025. Results will be published on GOV‌‌‌.UK in September 2025 in the ‘Tell ABAB report’. The survey is commissioned annually by HMRC, although the ABAB is an independent body. The ABAB says it is passionate about listening to and understanding the needs of the small business community. Board members come from a range of businesses and professions, and their goal is to support HMRC to make the tax system quicker and simpler for small businesses. If you have any questions about the 2025 survey, please email advisoryboard.adminburden@hmrc.gov.uk.

Last week we reported that ‘L-day’ will take place today, Monday 21 July 2025. The timing of this is expected to be late afternoon when we expect to see draft Finance Bill clauses on a range of pre-announced tax policy changes. Full coverage of L-day, also referred to as legislation day, will feature in Chartered Accountants Tax News next Monday 28 July.

In April this year, the Institute’s NI Tax Committee wrote to the Exchequer Secretary to the Treasury to raise its concerns about the disproportionate impact of the proposals to curtail the benefit of agricultural property relief and business property relief from April 2026, particularly in Northern Ireland, on genuine farming activity and family owned businesses. The Committee urged the Government to postpone the changes in order to consult wider and reframe this policy change in a way that it is more effectively targeted. Last week HM Treasury responded to the letter which you can read in full on our website. Unfortunately, the content of the letter suggests that the policy will be proceeding as planned, and there is no suggestion that there will be any mitigations to the draft policy as it currently stands. It is therefore possible that later today, draft Finance Bill clauses for this policy change will be published as part of ‘L-day’. The Institute is therefore considering what further action needs to be take on this important issue. In April, the NI Tax Committee also responded to the related technical consultation which took place earlier in the year.

The Financial Reporting Council (FRC) has published FRED 87 Draft amendments to FRS 102  The Financial Reporting Standard applicable in the UK and Republic of Ireland. FRED 87 proposes amendments to FRS 102 to reflect recent amendments to IAS 1 Presentation of Financial Statements and the subsequent replacement of IAS 1 with IFRS 18 Presentation and Disclosure in Financial Statements. Specifically, it proposes changes to the prescribed formats for balance sheet and profit and loss accounts where an entity applying FRS 102 uses the option to adapt the presentation format. The changes are proposed to maintain the existing level of alignment with IFRS 18 and IAS 1. Entities that choose not to adapt their financial statements under FRS 102 will not be impacted by the proposed amendments. FRED 87 remains open for public comment until 10 October 2025.

Minister Burke has signed into law Statutory Instrument S.I. No. 309/2025- European Union (Corporate Sustainability Reporting) Regulations 2025. The purpose of this Statutory Instrument (S.I.) is to transpose the ‘stop the clock’ EU Directive into Irish law and to amend the anomalies that were present in previous S.I.s relating to the transposition of the Corporate Sustainability Reporting Directive (CSRD) in Ireland.   By way of background the Corporate Sustainability Reporting Directive (CSRD) became law in 2023, and it was transposed into Irish law in July 2024 by virtue of S.I. No. 336/2024 - European Union (Corporate Sustainability Reporting) Regulations 2024 (and subsequently S.I. No. 498/2024 - European Union (Corporate Sustainability Reporting) (No. 2) Regulations 2024, which amended some of the previous legislation)  There were a number of anomalies in these regulations which caused concern and challenges for businesses implementing the CSRD. The Institute, along with other professional bodies and law firms, made numerous representations to the Department of Enterprise, Tourism and Employment outlining the amendments that were required to give clarity on the implementation of the CSRD. The ‘wave 1’ reporters which were subject to the CSRD published their first sustainability statements earlier this year. Just as they were being published the European Commission published their ‘omnibus simplification package’ the purpose of which is to simplify sustainability reporting, and it also included a proposal to ‘stop the clock’ by delaying the commencement of reporting obligations by two years for the majority of companies.   The current state of play  Minister Burke recently published statutory instrument S.I. 309/2025, European Union (Corporate Sustainability Reporting) Regulations 2025 to transpose these changes into Irish law.   A summary of the changes are as follows:  ‘Stop the clock’: The S.I. transposes this EU Directive into Irish law and delays the application of the CSRD for the majority of Irish companies (wave 2 and wave 3) by two years. Large Irish incorporated entities will publish their first report in 2028 based on data for the 2027 financial year. SMEs with securities listed on an EU regulated market, small and non-complex institutions, captive insurance and reinsurance undertakings will issue their first reports in 2029 based on data for the 2028 financial year.  Definition of net turnover: The definition of ‘net turnover’, which is one of the thresholds for determining if a company is in scope for CSRD reporting, has been amended. The initial definition of turnover was broader in scope and for companies whose ordinary activities included the making or holding of investments, the gross revenue derived from such activities. Therefore, there were a number of companies, primarily in the funds sector and Special Purpose Vehicles, which were captured which may not otherwise have fallen within scope of the CSRD. The revised definition aligns more closely with the definition of ‘net turnover’ under the EU Accounting Directive.  Ineligible entities: Under the original S.I. relating to the CSRD, there was confusion in Ireland regarding  ‘ineligible entities’ and if they were potentially in scope for CSRD reporting irrespective of their size. The revised regulations expressly exclude these from scope and ‘ineligible entities’ are only in scope for the CSRD if they meet the CSRD thresholds.  Subsidiary exemptions: There was uncertainty under the original transposition as to whether or not an Irish subsidiary could claim a subsidiary exemption if its sustainability information was included in the consolidated report of an EU parent company. In the revised regulations the provisions on subsidiary exemptions have been expanded, consistent with the CSRD, so that an Irish in-scope company may be exempt from preparing its own sustainability report where the information is included in the report of an EU parent, drawn up in accordance with the consolidated sustainability reporting obligations of the EU Accounting Directive, as amended by the CSRD.  Ultimate parent company reporting: There was, in the initial CSRD regulations, the potential that all non-EEA parent companies of certain Irish companies had to prepare a sustainability report, and not just the ‘ultimate parent company’. The revised regulations have provided clarification on this matter and there is a new definition of ‘ultimate parent company’, and only that company now must prepare a report. The timeframe has not been amended by the revised regulations, and reporting obligations in respect of non-EEA undertakings apply beginning on or after 1 January 2028.

Institute representatives Judith Condell and Cróna Clohisey attended the launch of the third Annual Report of the Women in Finance Charter. The Institute is proud to be one of 100 signatories to the Charter: an industry-led and Government supported initiative aimed at increasing women's participation at all levels of business in financial services in Ireland. The Report was launched at an event in Dublin by An Taoiseach Micheál Martin with Minister of State Robert Troy and is an important milestone highlighting the significant progress that has been made since the Charter was established in 2022. For example, since the first organisations signed up: 43.4% of senior management roles in signatory firms are now held by women – up from 36.2% Female board representation has risen from 30.3% to 36.3% CEO-level representation has increased from 19.4% to 22.6% The Institute believes in and is committed to gender diversity at all levels of our organisation, and is proud to be a signatory to the Charter. As Ireland strives for greater inclusion and competitiveness, this Charter is a powerful driver of change.  The Report can be read in full here.