In Irish news today, the Institute, under the auspices of the CCAB-I, has responded to the public consultation on the tax treatment of interest in Ireland and we bring you an update from Revenue on compliance information provided to taxpayers and businesses. In UK news, HMRC has issued an update for those severely impacted by the recent exceptional weather events, and it confirms it is not proceeding with plans requiring employers to provide more detailed employee hours data. In International news, the OECD has published guidance on the operation and management of a tax administration audit program. Ireland 1. Read the response by the Institute to the public consultation on the tax treatment of interest in Ireland. 2. Revenue is to write to non-filers of income tax and corporation tax returns. UK 3. HMRC contacts the Institute advising it will take a pragmatic approach to late filing for those affected by the recent exceptional weather. 4. In line with the Institute’s recommendation, HMRC confirms it is not proceeding with plans requiring employers to provide more detailed employee hours data. International 5. The OECD have recently published the VITARA Reference Guide on The Audit Program which provides guidance on a tax administration audit program. Keep up to date with all the latest Irish, UK, and international tax developments through Chartered Accountants Ireland’s Tax Newsletter. Subscribe to the Tax News by updating your preferences in MyAccount. You can also read this week’s post EU exit corner.            

Revenue has recently updated two other Tax and Duty Manuals. Details are set out below. The manual on the Exemption of the Annual Allowance for reserve members of the Garda Síochána is updated to provide for the continuation of this Income Tax exemption for reserve members of the Garda Síochána. The manual on Charges on Income for Corporation Tax purposes has been updated to include a new section dealing with the dissolution of companies.

Last Monday we highlighted that the Institute would be contacting HMRC to flag our concerns about the 2023/24 self-assessment online filing deadline in the context of the recent exceptional weather. We asked HMRC to take a pragmatic approach to this issue given the particular impact this has had on taxpayers, businesses, and agents in Northern Ireland and their ability to file returns on time. HMRC contacted us last Thursday with an update which confirms that whilst a blanket easement is not possible, HMRC will take a sympathetic approach towards those filing after the deadline on a case-by-case basis. HMRC has also advised that if a return is late because a taxpayer applied before 31 January 2025 for confirmation of available overlap relief in the context of basis period reform, they have until 28 February 2025 to file their return without incurring a late filing penalty. More information on this is available in the most recent Stakeholder Digest. The Institute recommends that if a return is filed late because of the recent weather, the additional information box should be completed to outline the specific reason(s) why and claim reasonable excuse. Further guidance is available in the Stakeholder Digest on delayed overlap relief requests and what action to take when filing a return late. The full update from HMRC on the impact of the exceptional weather is as follows: “Thank you for raising the possible impacts of the recent severe weather across parts of Ireland and the UK on people and businesses in the run up to the Self-Assessment deadline. Undoubtedly, this would have impacted some individuals, businesses and agents still trying to submit SA returns. Given the timing of these very recent events and the fact that areas most impacted are difficult to identify, we are not in a position to invoke a unilateral easement. We will however take a sympathetic approach towards those filing after the deadline on a case by case basis. We don’t want to collect penalties – our aim is to support taxpayers to get their tax right and avoid fines. We will cancel penalties where taxpayers can provide a reasonable excuse within 30 days of the penalty being issued, in which case no financial fine is levied. We will of course take into account the impact of adverse weather when it comes to such appeals. We will also take steps to ensure that teams reviewing forthcoming appeals are alert to the detail of the guidance and will apply it empathetically, appropriately and consistently. Please be reassured that HMRC will be delivering a fair, even-handed and consistent approach across everyone impacted in whatever capacity.” By way of reminder, those without a reasonable excuse will be issued with a penalty including: an initial £100 fixed penalty, which applies even if there is no tax to pay, or if the tax due is paid on time, after 3 months, additional daily penalties of £10 per day, up to a maximum of £900, after 6 months, a further penalty of 5 percent of the tax due or £300, whichever is greater, and after 12 months, another 5 percent or £300, whichever is greater. 31 January 2025 was also the due date for paying any remaining income tax and Class 4 national insurance contributions for 2023/24 and is also the first self-assessment payment on account deadline for 2024/25.

Revenue has updated the Tax and Duty Manual Exemptions and Reliefs from Stamp Duty to provide guidance on the exemptions available to state financing agencies and funds. An appendix has also been added to the manual which provides a complete list of the reliefs and exemptions included in Part 7 Stamp Duty Consolidation Act 1999

Revenue has updated the Tax and Duty Manual Charitable Tax Exemption to reflect amendments arising from Finance Act 2024. The main changes are as follows: A new paragraph has been included to provide for a charity to accumulate funds for charitable purposes and still retain its charitable exemption. To retain the exemption in these circumstances, the charity must expend the income by the end of the fifth year after the year in which the income was received, and The two-year waiting period for eligibility for the Charitable Donation Scheme (CDS) has been removed. In circumstances where a charity has merged or re-organised into another entity, it is no longer a requirement that the predecessor entity must have been approved for the CDS for two years.

Revenue has updated the Tax and Duty Manual Rent Tax Credit to reflect Finance Act 2024. The updated manual reflects the increase in the rent tax credit from 1 January 2024 to €1,000 for a single person and €2,000 for a jointly assessed married couple/civil partners. As the increase applies retrospectively from 1 January 2024, the manual also outlines how to make a claim for the increased credit for 2024. Relevant examples in the manual have also been updated to reflect the increased credit.

Revenue has updated the Tax and Duty Manual Universal Social Charge (USC) to reflect Finance Act 2024. The main changes to the manual are to reflect the increase in the rate thresholds and the reduction in the USC rate of four percent to three percent. Relevant examples in the manual are updated for these changes. The list of payments exempt from USC has also been updated.

The Taoiseach, Micheál Martin, has appointed Maura Kiely as Revenue Commissioner to succeed Gerry Harrahill. Maura joined Revenue in 2017 and previously worked with the Central Bank and in private practice.

Revenue has confirmed that they are aware of the difficulties the recent exceptional weather may have caused for the timely tax compliance of adversely impacted taxpayers and businesses. Revenue has also indicated that when agreeing flexible payment arrangements, they will take into consideration the financial circumstances of those impacted and particularly those who are experiencing temporary cash flow difficulties. The Press Release confirms that impacted taxpayers and businesses should contact the Collector-General’s office once their situation permits, to agree mutually agreeable arrangements for restoring timely tax compliance.

Revenue has informed us that notices will be issued to taxpayers who are currently registered for income tax or corporation tax and who have not filed income tax or corporation tax returns for years up to and including 2023. The notice is a Level 1 Compliance Intervention in accordance with Revenue’s Compliance Intervention Framework. Revenue is reminding taxpayers that the non-filing of a required tax return can result in a more detailed review by Revenue and is a prosecutable offence.   Agents will receive a single notification in their ROS inbox, listing their clients who have been issued the notice, together with a reminder for agents to file any outstanding returns for their clients.

Last week, the Institute, under the auspices of the CCAB-I, responded to the public consultation on the tax treatment of interest in Ireland. In our response, we stated the need for significant reform in order to remain competitive within the global race for talent and investment. As such, our most important proposal was our recommendation for a direction of travel which ends in a system which allows all commercial interest as a tax-deductible expense, whether trade-related or not, subject to the limitations described in the Interest Limitation Rule and the Anti-Hybrid Rules. The key policy rationale for such a move is the inherent protection afforded to the tax base in these rules. In our view, such a move presents an opportunity for a world-class and robust system to govern the taxation of interest in Ireland. The consultation looked at the taxation of both interest income and interest expenses, with every aspect of the Taxes Consolidation Act 1997 relevant to interest considered. The overall structure of the consultation was twenty-seven questions across the following broad headings: Taxation of Interest Income Interest Deductibility ATAD Interest Limitation Rule Anti-avoidance provisions and other restrictions Financial Services Transactions Withholding Tax Reporting Obligations Reforming Existing Interest Regime We made recommendations under each heading, however we have also been conscious of the need for caution in what is a complex and carefully balanced area of taxation. Our proposal for a system based around the Interest Limitation Rule and the Anti-Hybrid rules reflects the opportunity to choose a new way of taxing commercial interest which should not prejudice taxpayers and their existing arrangements. We hope that this consultation will form part of a wider and ongoing process of stakeholder engagement in the months and years ahead. As always, we will keep you updated via Tax News.

Following on from our story on Monday in which we highlighted the Institute’s plans to flag our concerns about the 2023/24 self-assessment online filing deadline to HMRC in the context of the recent storms, the Institute requested that HMRC take a pragmatic approach to this issue. We can now share the outcome of those discussions after receiving an update from HMRC. This confirms that whilst a blanket easement is not possible, HMRC will take a sympathetic approach towards those filing after the deadline on a case by case basis. The Institute therefore recommends that if a return is filed late because of the recent weather, the additional information box should be completed to outline the specific reason(s) why and claim reasonable excuse. HMRC will therefore cancel penalties where taxpayers can provide a reasonable excuse. The full update from HMRC is as follows: “ Thank you for raising the possible impacts of the recent severe weather across parts of Ireland and the UK on people and businesses in the run up to the Self Assessment deadline. Undoubtedly, this would have impacted some individuals, businesses and agents still trying to submit SA returns. Given the timing of these very recent events and the fact that areas most impacted are difficult to identify, we are not in a position to invoke a unilateral easement. We will however take a sympathetic approach towards those filing after the deadline on a case by case basis. We don’t want to collect penalties – our aim is to support taxpayers to get their tax right and avoid fines. We will cancel penalties where taxpayers can provide a reasonable excuse within 30 days of the penalty being issued, in which case no financial fine is levied. We will of course take into account the impact of adverse weather when it comes to such appeals. We will also take steps to ensure that teams reviewing forthcoming appeals are alert to the detail of the guidance and will apply it empathetically, appropriately and consistently. Please be reassured that HMRC will be delivering a fair, even-handed and consistent approach across everyone impacted in whatever capacity.” By way of reminder, those without a reasonable excuse will be issued with a penalty including: an initial £100 fixed penalty, which applies even if there is no tax to pay, or if the tax due is paid on time, after 3 months, additional daily penalties of £10 per day, up to a maximum of £900, after 6 months, a further penalty of 5 percent of the tax due or £300, whichever is greater, and after 12 months, another 5 percent or £300, whichever is greater. 31 January 2025 is also the due date for paying any remaining income tax and Class 4 national insurance contributions for 2023/24 and is also the first self-assessment payment on account deadline for 2024/25.

On Tuesday, 18 March 2025, the European Commission and the European Parliament will co-host the third EU Tax Symposium. The event is to bring together finance ministers, politicians, policymakers, academics and others to discuss the future of EU tax systems under the theme Strengthening Competitiveness and Fairness to Build Prosperity. Registration is now open for the symposium which will take place in Brussels and will also be livestreamed.

Following his inauguration on 20 January 2025, the President of the United States of America, Donald Trump, has published the Presidential Actions. The publications include a Memorandum on the OECD Global Tax Deal which states that the OECD’s Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy has no force or effect in the United States.

Recent trends The Institute’s Professional Standards Department has recently seen an increase in the frequency and complexity of proposed restructures of accounting and audit firms including: Institute firms acquiring or merging with other accounting and audit firms; Changes in a firm’s principals (retirements, additions); Creation of new firms within a firm network structure (including the splitting of an existing firm into a number of smaller firms sometimes with a focus on a particular business line or jurisdiction); Interests in a firm being fully or partially acquired by larger firms or other external investors including the involvement of private equity investors in firm/network ownership structures. These trends are observed in both Ireland and the UK. Early engagement with the Institute advised Firms who are considering a change in the firm’s structure or ownership are advised to engage with the Institute’s Professional Standards Department at an early stage in the process.  Such early engagement is important to ensure that any impact on existing or proposed firm authorisations, and/or on the AML supervision of any entities in the structure, is fully understood and properly planned for.  Law and Institute Regulations in both Ireland and the UK set out detailed eligibility criteria which must be met by firms authorised in reserved areas such as audit and investment business.  These eligibility criteria include specific requirements regarding the qualifications of principals and those having ownership/control at authorised firms.  While Institute Regulations require firms to notify the Institute promptly after a change in circumstance which could impact authorisations takes place, firms will benefit from early engagement with the Institute in relation to proposed restructuring transactions.  Firms will, no doubt, want to avoid a situation where a significant transaction concerning the firm’s structure has taken place only to discover that the revised structure negatively impacts the firm’s eligibility for authorisation in a key area. Firms considering a restructure should contact the Institute at authorisations@charteredaccountants.ie.  The Institute will advise the firm regarding the information which should be shared with the Institute initially and as the restructuring plans progress.  The Institute will request information to enable a full understanding of the proposed restructure and the impact on the firm’s eligibility for authorisation(s).  Such information is likely to include the detailed agreements and documentation underlying a transaction such as revised partnership agreements, constitutional documents such as articles of association and where relevant, service level agreements between entities within the revised structure. Frequently, the complexity of restructuring transactions requires that the Institute dedicates significant time to review the relevant documentation, engage with the firm’s principals and conclude in relation to ongoing or new authorisations as a result of a firm restructure.  A firm’s engagement with the Institute early in the restructuring process helps ensure sufficient time for Institute consideration and for the processing of any new applications for individual or firm authorisations arising. The Institute cannot provide legal advice in relation to potential firm structures.  The Institute assesses information provided to conclude whether the Institute can continue to provide authorisations to the restructured firm(s) in reserved areas in accordance with the Institute’s Regulations. Oversight bodies In certain cases, it may also be appropriate for a firm and/or the Institute to engage with relevant oversight bodies such as IAASA or the FRC.  For example, an audit firm which is registered with the FRC as a UK public interest entity (PIE) auditor will be obliged to share information with the FRC in relation to a transaction which could impact UK audit registration. Fees For new notifications of restructuring arrangements received on or after 1 January 2025, the Institute may charge a separate fee to firms for the consideration of the impact of a firm restructure on a firm’s authorisations in reserved areas and/or on AML supervision where relevant.  The fee will be dependent on the complexity of the proposed restructure and the work involved in the Institute’s assessment of all relevant information.  This fee will contribute to the cost incurred by the Institute in the consideration of the proposed restructure and may include a contribution towards any legal advice which the Institute needs to undertake in this regard. Further information Any queries in relation to any of the matters raised above can be directed by email to authorisations@charteredaccountants.ie

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 latest Brexit and Beyond newsletter from the Northern Ireland Assembly EU Affairs team. Readers are again reminded that from 31 January 2025 an entry summary declaration (ENS) must be submitted for goods imported from the EU to Great Britain (GB). Also from the same date, HMRC has issued an email reminder about the new safety and security declarations required for all EU imports into GB. Entry summary declarations required for certain imports from 31 January 2025 HMRC is encouraging businesses involved in importing from the EU into GB to familiarise themselves with the new ENS requirements and has provided a summary of the key information. Detailed guidance is also available on GOV.UK. Miscellaneous guidance updates and publications How to claim a repayment of import duty and VAT if you've overpaid, Check if a business holds Authorised Economic Operator status, Make an entry summary declaration using the Import Control System 2, Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service, and Appendix 1: DE 1/10: Requested and Previous Procedure Codes of the Customs Declaration Service (CDS).

In this week’s miscellaneous updates, a new independent review of the loan charge has been announced by HMRC Treasury to bring the issue to a close. HMRC has issued a clarification about certain company tax returns submitted before 10 September 2024 and the Public Accounts Committee has recently opened an inquiry into the cost of the tax system. The latest schedule of HMRC Talking Points live and recorded webinars for tax agents are available for booking. Spaces are limited, so take a look now and save your place. And finally, check HMRC’s online services availability page for details of planned downtime and the online services affected. New loan charge review Last week HM Treasury announced that a new independent review into the loan charge has been launched (23 January) when the Exchequer Secretary to the Treasury (XST) in a Written Ministerial Statement announced that Ray McCann, a former President of the Chartered Institute of Taxation, will lead the review. The review will examine the barriers preventing those who are subject to the loan charge reaching resolution with HMRC where they have not already settled and paid their tax liabilities in full. It will also recommend ways in which they can be encouraged to settle with HMRC. The reviewer is tasked with reporting and presenting their recommendations to the XST by Summer 2025. The terms of reference of the review set out the context, scope, and objectives of the independent review in more detail. The review team can be contacted at contact@lcreview2025.org.uk. The following publications provide more detail on the review: Independent review of the loan charge, and Loan charge review launched. Company tax returns submitted before 10 September 2024 On 10 September 2024, HMRC updated its guidance on how to complete a company tax return for accounting periods straddling 1 April 2023. This required companies to use box 326 (and not box 625) to report the number of related 51 percent group companies. HMRC has now clarified that returns submitted before 10 September 2024 do not need to be amended to reflect the updated guidance. New Public Accounts Committee (PAC) inquiry into the cost of the tax system The PAC is conducting an inquiry into the cost of the tax system. The PAC has recently been scrutinising HMRC’s customer services, underpinned by the National Audit Office (NAO) findings in 2024 that delivering responsive customer service continued to be one of HMRC’s biggest challenges. The NAO is also currently undertaking a project which will report on drivers of cost in the tax system which is expected to be published shortly in winter 2024/25. The study aims to help understand how elements of the tax system drive these costs, while establishing what progress HMRC has made in reducing costs and improving efficiency.  Based on the NAO report, the PAC expects to hear from senior HMRC officials on topics including:  What costs the UK tax system imposes on HMRC taxpayers and their intermediaries, Challenges in tackling the costliest parts of the system, and   How HMRC is taking opportunities to reduce costs.  The PAC has published the requirements for written evidence submissions as part of its inquiry and advises that it is unable to accept material as evidence that is published elsewhere. 

This was the key recommendation of the Institute’s Northern Ireland Tax Committee in its response to the HMRC consultation ‘The Tax Administration Framework Review - new ways to tackle non-compliance’. This consultation proposes several amendments to existing powers/potential new powers for HMRC including partial enquiries, amendments to the conditions for making certain claims, reform of Revenue Correction Notices and a power to require taxpayers to self-correct. The Committee also took the opportunity to highlight the lack of progress being made on tax simplification and made a number of recommendations to reduce tax complexity. The Committee’s key recommendations can be read on page 9 and in summary are as follows: A full review of HMRC’s existing powers, deterrents, and safeguards should be undertaken, and their associated administration processes, before any changes are made to existing powers, or any new powers are introduced, A range of measures should be undertaken to tackle tax complexity, which should as a minimum include the establishment of a Tax Simplification External Forum which reports annually to Parliament, HMRC should consider the possibility of requiring certain large employers to claim flat rate expenses on behalf of their employees via PAYE Real Time, HMRC should consider if a system could be implemented in the UK for claiming relief for employment expenses by enabling supporting evidence to be uploaded to the taxpayer’s Personal Tax Account with services also available to agents, The time limit within which a taxpayer can reject a Revenue Correction Notice should be longer and should not begin until it has been received by the taxpayer, HMRC should not introduce partial enquiries for the reasons cited in the submission. Overall, the Committee concluded that more broad ranging reform of HMRC’s compliance powers appears to be warranted similar to the different levels of compliance interventions in Ireland which include voluntary self-correction powers for non-deliberate errors by taxpayers.

The 2023/24 self-assessment online filing deadline is in just four days’ time on Friday 31 January 2025. The Institute is aware of the impact of Storm Eowyn and its aftermath on the ability of taxpayers and agents to file returns on time and will be flagging this to HMRC to ask it to take a pragmatic approach as the fallout from the storm continues into this week. We will update members in the news section of our website. On Thursday 23 January just the day before the Storm, HMRC was warning that 3.4 million returns remained unfiled. By way of reminder, taxpayers who provide HMRC with a reasonable excuse may avoid a penalty for filing late. However, those without a reasonable excuse will be issued with a penalty including: an initial £100 fixed penalty, which applies even if there is no tax to pay, or if the tax due is paid on time, after 3 months, additional daily penalties of £10 per day, up to a maximum of £900, after 6 months, a further penalty of 5 percent of the tax due or £300, whichever is greater, and after 12 months, another 5 percent or £300, whichever is greater. 31 January 2025 is also the due date for paying any remaining income tax and Class 4 national insurance contributions for 2023/24 and is also the first self-assessment payment on account deadline for 2024/25.

Mentorship is key for young accountants transitioning to business development, offering guidance on effective networking, client engagement and relationship-building, says Mary Cloonan The challenge can feel significant for young accountants stepping into roles with business development targets for the first time. New responsibilities, particularly those requiring skills like networking and relationship-building, are often far removed from their previous technical focus. This is where mentorship can help, providing guidance and support to help them grow into the demands of their new role. Business development requires more than technical expertise. It involves cultivating relationships, strategic thinking and communicating value—skills not typically part of an accountant’s formal training. A mentor can: Provide practical guidance: Teach the mentee how to approach client engagement, network effectively and communicate persuasively. Build confidence: Support them as they tackle new challenges and unfamiliar scenarios. Set the example: Offer insights through real-world experiences and professional behaviour. Align efforts with strategy: Help them understand how their contributions support the firm’s broader goals. Effective mentoring: seven steps Here are seven steps experienced accountants can take to be a good mentor. 1. Simplify the starting point Break down business development into manageable steps. Help your mentee see this as relationship-building exercise rather than purely sales-focused. Concentrate on: Recognising potential opportunities in their network. Understanding the firm’s unique value proposition. Developing a genuine interest in client needs. 2. Set measurable goals Define clear and realistic targets. For example: Attend one networking event per month. Schedule two introductory meetings with prospective clients. Contribute to a team pitch or proposal. These bite-sized goals can help to build momentum without overwhelming them. 3. Practice through role-play Simulated scenarios are invaluable for building confidence. “Practice” situations with your mentee, such as: Introducing themselves at events. Explaining the firm’s services to a potential client. Handling objections effectively. Role-playing in a safe environment can help to prepare them for real-world challenges. 4. Encourage observation Let your mentee shadow experienced professionals. Whether it’s a client meeting, negotiation or event, watching mentors in action is a powerful learning tool. Follow up with discussions to reinforce key takeaways. 5. Emphasise listening Strong business development is rooted in active listening. Encourage them to: Ask open-ended questions. Pay close attention to what clients are really saying. Build trust by understanding challenges from the client’s perspective. 6. Give constructive feedback Feedback is essential. Review your mentee’s performance after meetings or pitches— highlight strengths and suggest improvements. Recognising small wins can boost confidence and foster growth. 7. Highlight the bigger picture Help your mentee to connect their efforts with your firm’s success. Discuss how building relationships can drive growth, create opportunities for cross-selling and enhance career prospects. Benefits for both mentors and mentees An effective mentorship programme benefits everyone. Firms gain future leaders with technical and business development skills, while clients will likely experience better service through improved relationship management. For young accountants, developing these skills early can boost their confidence and open up potential avenues to career advancement. Mary Cloonan is Founder of Marketing Clever