From the Professional Accountancy team The President signed the Companies (Corporate Governance, Enforcement and Regulatory Provisions) Bill 2024 into law on 12 November 2024. Provisions which will be of interest to our members were outlined in our news item in March 2024 following publication of the general scheme of the Bill .These include change in the rules regarding loss of audit exemption, provisions relating to receivers, some new grounds for company strike off and provisions regarding registered office and electronic filing agents.  Following publication of the draft Bill in August 2024 we did a further update on the Bill noting that most but not all of the provisions of the General Scheme had been included in the Bill .Click for the August 2024 updated news item.  At the time of writing, publication of the legislation on the Irish Statute Book as passed  and details of its commencement into law is awaited.This should be available very shortly and we will provided further updates when information on this is made available. 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.    

The IAASB has published the much anticipated ISSA 5000 International Standard on Sustainability Assurance 5000, General Requirements for Sustainability Assurance Engagements.  This standard is a comprehensive, stand-alone standard suitable for any sustainability assurance engagements. It will apply to sustainability information reported across any sustainability topic and prepared under multiple frameworks. The standard is also profession agnostic, supporting its use by both professional accountants and non-accountant assurance practitioners. The draft standard was subject to a public consultation in 2023 and Chartered Accountants Ireland's response can be read here. 

Chartered Accountants Ireland has today launched its new guide to Foreign Direct Investment (FDI) in Ireland at an event in conjunction with IDA Ireland in Dublin.  Over 100 attendees gathered in Chartered Accountants House to hear from a panel of: Cróna Clohisey, Director of Public Affairs Chartered Accountants Ireland Feargal O'Rourke, Chair, IDA Ireland Barry Doyle, President Chartered Accountants Ireland Ireland faces greater competition as a location for global FDI than ever before as we move into 2025, with other countries enhancing their offering at pace. While Ireland’s FDI policy has stood the country in good stead for decades, a slowdown in growth of the global economy coupled with accelerated industrial policy interventions by competitor countries means Ireland’s inward investment model is now at a crucial inflection point. Commenting at the event, Cróna Clohisey, Director Public Affairs, Chartered Accountants Ireland said “Ireland’s record of attracting FDI has been the envy of other countries for decades and IDA Ireland has played a pivotal role. However, against a backdrop of heightened geopolitical uncertainty and intensifying global competition for inward investment, we cannot afford to be complacent about our offering. The significant deficits in the State’s crucial infrastructure, including housing, energy, water, childcare and nationwide public transport, need to be addressed with urgency if we are to remain fully competitive in the race for future FDI.” Barry Doyle, President, Chartered Accountants Ireland said “We are all familiar with the advantages that Ireland holds in attracting FDI - EU membership, strategic location, young talented workforce and a stable business environment. Our members also represent a key competitive advantage, with Chartered Accountants playing a central role in supporting FDI the length and breadth of the country. “Competition has never been greater for the flow of FDI around the world, and with a new US administration taking office in a matter of weeks, there is an increased chance of disruption to the traditional flow of FDI globally. However, investors with a long term, sustainable outlook will look beyond short-term protectionism. Ireland as a safe and stable environment will continue to benefit greatly from FDI and we as Chartered Accountants will be there to lead and support such investments.”

Increased global competition one of several challenges to FDI model Addressing infrastructural deficit critical to ensuring continued FDI growth Chartered Accountants Ireland launches FDI guide, highlighting critical role its members play in supporting investment   Ireland faces greater competition as a location for global Foreign Direct Investment (FDI) than ever before as we move into 2025, with other countries enhancing their offering at pace. While Ireland’s FDI policy has stood the country in good stead for decades, a slowdown in growth of the global economy coupled with accelerated industrial policy interventions by competitor countries means Ireland’s inward investment model is now at a crucial inflection point, according to Chartered Accountants Ireland.  The Institute, the largest professional body on the island of Ireland, representing over 38,400 members, has today launched its new guide to FDI in Ireland at an event in conjunction with IDA Ireland in Dublin.   Cróna Clohisey, Director Public Affairs, Chartered Accountants Ireland said  “Ireland’s record of attracting FDI has been the envy of other countries for decades and IDA Ireland has played a pivotal role. However, against a backdrop of heightened geopolitical uncertainty and intensifying global competition for inward investment, we cannot afford to be complacent about our offering. The significant deficits in the State’s crucial infrastructure, including housing, energy, water, childcare and nationwide public transport, need to be addressed with urgency if we are to remain fully competitive in the race for future FDI.” Barry Doyle, President, Chartered Accountants Ireland said  “We are all familiar with the advantages that Ireland holds in attracting FDI - EU membership, strategic location, young talented workforce and a stable business environment. Our members also represent a key competitive advantage, with Chartered Accountants playing a central role in supporting FDI the length and breadth of the country. “Competition has never been greater for the flow of FDI around the world, and with a new US administration taking office in a matter of weeks, there is an increased chance of disruption to the traditional flow of FDI globally. However, investors with a long term, sustainable outlook will look beyond short-term protectionism. Ireland as a safe and stable environment will continue to benefit greatly from FDI and we as Chartered Accountants will be there to lead and support such investments.”    

Finance Bill 2024/25 was published last week on 7 November. Explanatory notes to the Bill were also published. The Bill’s first reading in the House of Commons took place last week; second reading has not yet been scheduled.

Over the next five years, the Government is expanding HMRC’s capacity with the objective of closing the tax gap and bringing in an additional £6.5 billion per year by 2029/30. A range of announcements featured in this area including anti-avoidance legislation, and a commitment to overhaul HMRC’s IT systems and improve debt management by ensuring tax debt is settled faster. However, no information was provided on any specific additional investment to improve HMRC’s phone and post services. And finally, the expected consultation on e-invoicing will not be launched until early 2025. Investment in HMRC The HMRC settlement provides total funding of £6.7 billion in 2025/26. According to the Budget publications, the increased funding, together with the Exchequer Secretary to the Treasury becoming Chair of HMRC’s Board, marks a step change in the Government’s efforts to “close the tax gap, improve service levels, and modernise and reform HMRC”. Plans also continue to transform HMRC into a “digital‑first organisation”, with a Digital Transformation Roadmap to be published in Spring 2025. 180 new counter-fraud staff will be used to target increasing HMRC’s capability to better tackle fraud and error in child benefit and tax-free childcare via an expected gross saving of £95 million by 2029/30. As announced in July, £1.4 billion will be invested over the next five years to recruit an additional 5,000 HMRC compliance staff in order to raise £2.7 billion per year in additional revenue by 2029/30. The first 200 are set to join this month. £262 million will be invested over the same period to fund 1,800 HMRC debt management staff, with the aim of raising £2 billion per year in additional revenue by 2029/30. £154 million will be invested to modernise HMRC’s debt management case system and a £12 million investment will be used to acquire further credit reference agency data to enable HMRC to better target their debt collection activities. £16 million is to be invested to modernise HMRC’s app to allow income tax self-assessment taxpayers to make voluntary advance payments in instalments. The Government also confirmed that the use of payroll software to report and pay tax on benefits in kind (payrolling of BIKs) will become mandatory as previously announced. This will take place in phases, from April 2026 and will apply to income tax and Class 1A National Insurance Contributions. Tax agents £36 million is being invested in order to modernise HMRC’s tax adviser registration services from April 2026 and tax advisers who interact with HMRC on behalf of clients will need to be registered with HMRC. This will be legislated for in a future Finance Bill. From 6 April 2025, tax advisers will be required to provide an advanced electronic signature when making specified income tax repayment claims on behalf of clients. A consultation will also be published in early 2025 on options to enhance HMRC’s powers and sanctions to take swifter and stronger action against tax advisers who facilitate non-compliance. Umbrella company market To tackle “the significant levels of tax avoidance and fraud in the umbrella company market”, recruitment agencies will become responsible for accounting for PAYE on payments made to workers that are supplied via umbrella companies. Where there is no agency, this responsibility will fall to the end client business. This will take effect from April 2026. A policy paper was published alongside the Budget providing further information on this measure. Late payment interest rates on unpaid tax From 6 April 2025, the late payment interest rate charged by HMRC on unpaid tax liabilities will increase by 1.5 percent points so that it will be set at 4 percent above base rate. Should the current Bank of England base rate remain unchanged between now and then, the interest rate will therefore increase from 7.25 percent to 8.75 percent. Digital reporting for Individual Savings Account managers This will be mandatory from 6 April 2027; hence draft legislation will be published for a technical consultation in 2025. Car ownership schemes Draft legislation will be published to deal with loopholes in car ownership arrangements. This aims to target arrangements through which an employer/third party sells a car to an employee, often via a loan with no repayment terms and negligible interest, then buys it back after a short period. This will take effect from 6 April 2026. Charity compliance Legislation will be introduced to ensure that only the intended tax relief is given to charities. These changes will take effect from April 2026 to give charities time to adjust to the new rules. Liquidations of limited liability partnerships The way capital gains are taxed when a limited liability partnership is liquidated, and assets are disposed of to a contributing member or person connected to them, changed from 30 October 2024 and will be legislated for in Finance Bill 2024/25. Close company loans to participators The Government will ensure that shareholders cannot extract funds untaxed from close companies by legislating to remove opportunities to side-step the anti-avoidance rules attached to the loans to participators regime. This change applies from 30 October 2024. Reducing tax-free overseas transfers of tax relieved UK pensions The Government removed the exclusion from the overseas transfer charge for transfers to qualifying recognised overseas pension schemes in the European Economic Area or Gibraltar from 30 October 2024 to address the risk of individuals receiving double tax-free allowances. Rogue company directors Collaboration between HMRC, Companies House, and the Insolvency Service will be increased to tackle those using contrived corporate insolvencies and dissolutions, often referred to as “phoenixism”, to evade tax. Deterring tax fraud and rewards for informants HMRC’s counter-fraud capability will be expanded to address “high value and high harm tax” and its scheme for rewarding informants will be strengthened in order to encourage reporting of high value tax fraud and avoidance. Tackling promoters of marketed tax avoidance A consultation will be published in early 2025 on a package of measures to tackle promoters of marketed tax avoidance. Offshore tax compliance The Government committed additional resources to scale up compliance activity in order to tackle serious offshore non-compliance such as fraud by wealthy taxpayers and intermediaries, corporates they control and other connected entities. Simplification of taxation of offshore interest A consultation has been launched to tackle challenges arising from the mismatch of information on offshore interest being provided on a calendar year basis rather than a UK tax year basis. The consultation is seeking views on options to address this mismatch, including changes to the rules so that individuals are taxed on the non-UK interest arising in the year ended 31 December that ends in the tax year. Cryptoasset Reporting Framework and amendments to the Common Reporting Standard A summary of responses to the consultation on the implementation of the Cryptoasset Reporting Framework (CARF) and amendments to Common Reporting Standard was published. This includes a decision to extend the CARF’s reporting requirements to UK users. This will be legislated for in Finance Bill 2024/25, although draft regulations to implement the revised rules have already been published for consultation. Employee ownership trusts and employee benefit trusts A package of reforms to the taxation of employee ownership trusts and employee benefit trusts were introduced to prevent opportunities for abuse and ensure that the regimes remain focused on encouraging employee ownership and rewarding employees. These changes took effect from 30 October 2024. Hidden economy: expanding tax conditionality to new sectors and consultation on HMRC correction powers A consultation has been published on whether to make the renewal of further public sector licences conditional on applicants demonstrating they are appropriately registered for tax. The Government has also published a consultation on reforming HMRC’s correction powers, exploring changes to HMRC’s existing powers and processes, and a potential new power to require taxpayers to correct mistakes themselves. A response to the call for evidence on HMRC powers, penalties, and safeguards has also been published. Making better use of third-party data The Government will publish a consultation in early 2025 on modernising how HMRC acquires and uses third-party data. Requirements for European Economic Area overseas pension schemes The Government will bring in line the conditions of overseas pension schemes (OPS) and recognised overseas pension schemes (ROPS) established in the EEA with OPS and ROPS established in the rest of the world from 6 April 2025. UK resident pension scheme administrators The Government will require scheme administrators of registered pension schemes to be UK resident from 6 April 2026.  

A range of measures featured in this area including the announcement that the 100 percent first year allowance (FYA) for qualifying expenditure on certain green assets, including plant or machinery for electric vehicle charge points, will be extended, a recommendation of the Institute in its pre-budget submission. Green FYA The Government will extend for a further year the 100 percent FYA for qualifying expenditure on zero-emission cars and the 100 percent FYA for qualifying expenditure on plant or machinery for electric vehicle charge points to 31 March 2026 for corporation tax and 5 April 2026 for income tax. Leased assets and full expensing Extending full expensing to assets bought for leasing or hiring will be explored when fiscal conditions allow. What qualifies for capital allowances HMRC will continue to work with stakeholders to improve and clarify guidance on areas of uncertainty within the capital allowances system. Tax treatment of predevelopment costs A consultation will be launched in the coming months that explores the tax treatment of predevelopment costs.

The Government will engage with stakeholders over the coming months to understand their views on where the tax policy making process works well, and what could be improved. In its pre-budget submission, the Institute highlighted the need to examine the current tax policy making process. The Government is also committed to a single major fiscal event per year. According to the Budget publications, the Government will simplify the tax system and will take this forward as part of its three strategic priorities for HMRC. It plans to engage with stakeholders before introducing a set of measures to simplify tax administration and improve taxpayer experience in Spring 2025. This will focus on reducing burdens on small businesses. The Government will meet stakeholders to understand the priorities for administration and simplification, ensuring that this work is driven by the views of taxpayers.

As previously announced VAT on private school fees will proceed as planned from 1 January 2025. On the duty side, the expected increase in fuel duty has been shelved, as recommended by the Institute in its pre-budget submission. VAT on private school fees From 1 January 2025, all education services and vocational training provided by a private school in the UK for a charge will be subject to VAT at the standard rate of 20 percent This will also apply to boarding services provided by private schools. The Government has now published a response to its recent technical consultation on this policy. To protect pupils with special educational needs that can only be met in a private school, local authorities and devolved Government’s that fund these places will be compensated for the VAT they are charged on those pupils’ fees. VAT treatment of private hire vehicles The Government is considering the responses to the consultation on the VAT treatment of private hire vehicle services, and the impact of a recent Court of Appeal judgment and will respond to the consultation in due course. Fuel duty The Government is freezing fuel duty and extending the temporary 5p cut for one year, at a cost of £3 billion. This will save the average car driver £59 in 2025/26. Alcohol duty The Government recognises the economic and cultural importance of British pubs and is committed to supporting smaller brewers. The Budget therefore reduced duty on qualifying draught products from 1 February 2025, which represent approximately 60 percent of alcoholic drinks sold in pubs, cutting duty on an average strength pint by a penny. However, alcohol duty on non-draught products will increase in line with Retail Price Index (RPI) inflation from the same date. The current temporary wine easement will end as planned on 1 February 2025. To support small producers, the Government will make the small producer relief more valuable and will also consult on ways to encourage small brewers to retain and expand their access to UK pubs, maximising drinkers’ choice and local economies, including through provisions to enable more ‘guest beers’. The Government also announced the end of mandatory duty stamps for spirits and will consult with industry to establish how it can better support the delivery of the spirit drinks verification scheme, which allows spirit producers to verify the geographic origin of their products. This will include the Government making an investment of up to £5 million “to support and look to reduce bureaucracy for existing and prospective producers who may wish to join”. Air passenger duty To ensure Air Passenger Duty (APD) revenues remain sustainable, all APD rates will increase in 2026/27. This equates to £1 more for those taking domestic flights in economy class, £2 more for those flying to short-haul destinations in economy class, £12 for long-haul destinations, and relatively more for premium economy and business class passengers. The higher rate, which currently applies to larger private jets, will rise by a further 50 percent in 2026/27. From 2027/28 onwards, all rates will be uprated by forecast RPI and rounded to the nearest penny. The Government is also consulting on extending the scope of the APD higher rate to capture all passengers travelling in private jets already within the APD regime. Vehicle excise duty To help drive the transition to electric vehicles (EVs), the Government is strengthening incentives to purchase EVs by widening the differentials in vehicle excise duty (VED) first year rates between EVs and hybrids/internal combustion engine cars. The Government recognises the disproportionate impact of the current VED expensive car supplement threshold for those purchasing zero emission cars and will consider raising the threshold for zero emission cars only at a future fiscal event, to make it easier to buy electric cars. Heavy goods vehicle (HGV) VED rates will increase in line with RPI from 1 April 2025 as will the HGV levy. Smoking duty The tobacco duty escalator of RPI +2 percent is being retained for the remainder of this Parliament and will increase duty by a further 10 percent on hand-rolling tobacco this year. These changes apply from 6pm on 30 October 2024. A new vaping products duty will be introduced from 1 October 2026 at a flat rate of £2.20 per 10ml vaping liquid, accompanied by an equivalent further one-off increase in tobacco duty to maintain the financial incentive to switch from tobacco to vaping. Soft drinks levy The soft drinks levy will increase so that it maintains the incentive for soft drinks manufacturers to reduce their sugar content. Rates will be announced in the preceding autumn fiscal event. Both the lower and higher rates of the Levy will increase each year over the next five years to reflect the 27 percent Consumer Price Index (CPI) increase between 2018 and 2024, in addition to an increase in line with the CPI each year from 1 April 2025. The Government will also review the current sugar thresholds and the exemption for milk-based drinks. Gaming duty The gross gaming yield bandings for gaming duty will be frozen from 1 April 2025 until 31 March 2026. The Government will also consult in 2025 on proposals to bring remote gambling (meaning gambling offered over the internet, telephone, TV and radio) into a single tax, rather than taxing it through a three-tax structure. This will aim to simplify, future-proof and close loopholes in the system.  

A range of other measures also featured, included increases in certain stamp duty land tax rates from 31 October 2024. Stamp duty land tax (SDLT) The SDLT surcharge on acquisition of an additional dwelling increased from 3 percent to 5 percent from 31 October 2024. The 15 percent rate of SDLT that is charged on the purchase of dwellings costing more than £500,000 by corporate bodies increased by 2 percentage points to 17 percent from the same date. Those who exchanged contracts prior to 31 October 2024 are not affected by these rate increases. Van fuel and benefit charge and car fuel benefit Both of these will increase by the CPI from 6 April 2025. Plastic packaging tax To incentivise businesses to use recycled instead of new plastic in packaging, the Plastic Packaging Tax (PPT) rate for 2025/26 will increase in line with CPI inflation. To support the use of and investment in advanced chemical recycling technologies, businesses will be permitted to use a mass balance approach to evidence recycled content in chemically recycled plastic for the PPT. Landfill tax rates The previously announced adjustment to landfill tax rates from 1 April 2025, which maintains the incentive to manage waste more sustainably, will be implemented in order to maintain the real-terms value of landfill tax rates. To ensure they reflect up-to-date market and economic conditions, the Government will announce future landfill tax rates at the fiscal event immediately before, so that those applicable from 1 April 2026 will be announced at Budget 2025. Land remediation relief A consultation will be launched in Spring 2025 to review the effectiveness of land remediation relief and will consider whether the relief is still meeting its objectives and is good value for money. Rollover of 2021 business tariff suspensions Following feedback from businesses, the Government will maintain tariff-free imports to avoid unnecessary costs for UK businesses. This measure will extend, until June 2026, tariff suspensions on goods ranging from aluminium frames used by UK bicycle manufacturers to ingredients used by UK food producers. Alternative finance tax rules  Alternative finance tax rules will be amended to put certain tax consequences of alternative and conventional financing arrangements on a level playing field. This follows a consultation on tax simplification for alternative finance which the previous Government published a summary of responses to earlier in 2024. The changes apply UK-wide from 30 October 2024 and will be legislated for in Finance Bill 2024/25. Annual Tax on Enveloped Dwellings (ATED) The annual chargeable amounts for the ATED will increase by the September 2024 CPI figure of 1.7 percent in 2025/2026. This will be implemented via a Treasury Order. Private intermittent securities and capital exchange system - stamp taxes exemption The Government is committed to delivering the private intermittent securities and capital exchange system (PISCES), a new innovative market for trading private company shares. In line with that commitment, the Government announced that PISCES transactions will be exempt from Stamp Duty and Stamp Duty Reserve Tax. This exemption will be introduced via a similar timeline to the legislation which will establish the PISCES regulatory framework. Energy profits levy From 1 November 2024, the Energy Profits Levy (EPL) increased by 3 percentage points to 38 percent, the investment allowance was abolished, and the rate of the decarbonisation allowance was set at 66 percent, so that its cash value is maintained. To provide certainty and to support a stable energy transition, the Government will make no additional changes to tax relief available within the EPL regime and the levy will end on 31 March 2030. The Government will legislate for these measures in Finance Bill 2024/25. To support long-term stability and predictability in the oil and gas fiscal regime, the Government also plans to publish a consultation in early 2025 on how the taxation of oil and gas profits will respond to price shocks after the EPL ends. It will also continue to have regular engagement with the sector to understand the evolving context of oil and gas investment, supported by bi-annual fiscal forums. Relief for payments made into a carbon capture usage and storage decommissioning fund The Government will legislate in Finance Bill 2024/25 to provide relief for payments oil and gas companies make into decommissioning funds in relation to assets sold for use in carbon capture usage and storage, maintaining the tax treatment had these assets instead been decommissioned. This legislation will also remove receipts from the sale of these assets from the scope of the EPL. Consultation on scope 3 emissions The Government is consulting on new environmental guidance for assessing end use emissions related to oil and gas projects. This consultation seeks to provide stability for the oil and gas industry, support investment, protect jobs and ensure a fair, orderly and prosperous transition in the North Sea in line with climate and legal obligations. Climate change levy 2026/27  The main rates of the climate change levy (CCL) for gas, electricity, and solid fuels will increase in line with the Retail Price Index in 2026/27. The main rate for liquefied petroleum gas will continue to be frozen and the reduced rates of the CCL will remain at an unchanged fixed percentage of the main rates. Carbon price support 2026/27  Carbon price support rates in Great Britain will remain at a level equivalent to £18 per tonne of CO2 in 2026/27. Advance tax certainty for major projects A consultation will be launched in Spring 2025 to develop a new process that will give investors in major projects increased tax certainty in advance.  

Ireland’s economic future hinges on sustaining FDI, reforming regulations and tackling infrastructure issues to secure continued growth. Brendan Murphy explains why “It’s FDI, stupid” to paraphrase a 1990s US election slogan. We are a relatively small country – we need foreign direct investment to keep flowing in whether it is from the US or other parts of the world, including China. Over 80 percent of our corporation tax receipts and over 50 percent of our payroll tax receipts are generated by these companies. That money benefits all of us – consumers, savers and workers. We must not lose the golden goose.  This will require a long hard look at our infrastructure challenges in the coming decades, including some of the well-documented planning restrictions that can frustrate international businesses planning to set up in Ireland. The recent Government Budget missed an opportunity to champion Ireland’s businesses and entrepreneurs, featuring very few improvements to capital gains tax rules to encourage either. The cost of establishing and running a business continues to spiral. We would strongly support calls for improvements to entrepreneur relief to reward business owners and an easy-to-use share-based remuneration scheme that would allow those businesses to retain and reward key talent. Budget 2025 referred to four major issues that could make a real difference: share-based remuneration, the R&D tax credit, interest deductibility and the tax climate for the funds sector. In all four cases, however, the Government opted only to reference new and ongoing reviews rather than introduce any new tax policies. We think these should be top priorities for any incoming government to show some real tangible decisions from these reviews. Airport cap The airport cap has highlighted a key issue with planning laws and regulations in Ireland. This 17-year-old rule was introduced when Terminal 2 was built during a very different era. With a growing population and improvements to airport infrastructure, this cap should have been lifted years ago. We understand the need to manage this from an environmental perspective, but there is also a need to be mindful of the business travel that is crucial to maintaining our FDI levels and ensuring we support our hospitality sector, which felt forgotten and overlooked in the recent Budget.  We need to boost our tourist and investor numbers – not potentially put them off with higher air fares and fewer flights. Housing deficit There is no doubt housing will be a key battleground during this election and a key focus for the new government of whatever political makeup. In the recent Budget, the government outlined a roadmap for how current and future considerations from bank share sales will be allocated, emphasising a strong commitment to infrastructure spending. This investment is critical for achieving Ireland’s ambitious housing targets, with all agencies and commentators signalling that 60,000 new housing units will need to be completed annually to address the chronic undersupply. Despite these good intentions, however, planning delays and higher building costs continue to be significant constraints to meeting these targets. Some builders are unable to commence building unless they know they can deliver houses and apartments people can afford to buy. In addition to the generous budget allocations, planning regulations need to be closely examined and overhauled. Tangible policies over reviews To maintain Ireland’s status as an attractive FDI destination, decisive action is required. Infrastructure challenges, regulatory reform and thoughtful incentives for both entrepreneurs and international companies must be prioritised by any incoming government. Ireland’s economic future relies on supporting FDI, addressing the housing crisis and creating a business-friendly environment. If we are serious about growth, it’s time to replace reviews with real policy changes that meet the needs of today’s global economy. Brendan Murphy is Head of Tax at Baker Tilly Ireland 

Ruth McNamee explores how GenAI is transforming finance, automating tasks, enhancing decision-making and providing insights to deliver better business results The landscape of Generative Artificial Intelligence (GenAI) is changing at an unprecedented pace, offering companies a unique opportunity to drive innovation and secure competitive advantages. Among the various business functions poised to benefit from this technological revolution, the finance function stands out as ideal candidates for early adoption. The power of GenAI in finance GenAI has the potential to revolutionise finance functions by automating routine tasks, enhancing decision-making processes and uncovering valuable insights from vast datasets. From virtual assistants that facilitate chatting with data and documents through automated document processing, to automating financial reporting, the potential applications of GenAI are vast and varied. By implementing a structured and systematic approach, finance functions can improve efficiency and drive strategic growth. Initial steps: ‘TOM Light’ and enablement For organisations eager to start their GenAI journey, adopting a streamlined target operating model (TOM), or ‘TOM Light’, is an excellent first step. This can help organisations to quickly realise the benefits of GenAI without extensive initial investments or complex restructuring. By focusing on a few high-impact use cases, supported with a preliminary governance and technology set-up, finance teams can demonstrate the value of GenAI and build momentum for broader adoption. The GenAI revolution requires companies to actively support employees during the transition, convincing them of the benefits and initiating a cultural shift. New skill sets are in demand, and employees need to learn to use new GenAI systems effectively in a corporate context. To expand the pipeline with additional use cases and support the successful roll out of high-impact use cases, it can be beneficial to start by training an initial group of employees and then extend training step-by-step. A role-based upskilling initiative typically includes foundational and technical AI knowledge, complemented by practical use case ideation sessions — from small daily benefits to large-scale GenAI use cases. For example, knowing how to effectively create prompts and recognise potential applications for GenAI can create efficiencies in an accountant’s or controller’s daily tasks. Long-term vision: a comprehensive target operating model While ‘TOM Light’ offers a quick and effective entry point, long-term success with GenAI requires a more comprehensive TOM. This model should be designed to handle GenAI effectively and responsibly, ensuring the technology is integrated seamlessly into the organisation’s processes and culture. Key components of a comprehensive TOM include: Governance framework: establish clear guidelines for the responsible use of GenAI, including data privacy and security measures. Talent and skills development: invest in larger-scale enablement, building on the experience with the initial group to equip finance teams with the skills needed to leverage GenAI effectively. Technology infrastructure: build a robust and scalable technology infrastructure that can support the deployment and ongoing maintenance of GenAI solutions. Creating a roadmap for success With a TOM in place, organisations can develop a detailed roadmap outlining the steps needed to implement GenAI across the finance function.  The transformative potential of GenAI is undeniable, and finance functions are uniquely positioned to lead the way. By taking immediate action and adopting a structured approach, finance teams could drive innovation, enhance efficiency and create sustainable competitive advantage for their organisation. The time to embrace GenAI is now — don’t just observe the revolution, be a part of it. Ruth McNamee is Finance Transformation Director at PwC

EY’s new State of Sustainability report shows businesses have reached a tipping point on sustainability, revealing a significant shift in sentiment and behaviour, writes Derarca Dennis The EY State of Sustainability 2024 report has reveals an important shift in how Irish businesses view sustainability. Eighty-one percent of respondents reported a heightened focus on sustainability within their organisations over the past year, marking a 19 percent increase from the previous survey in 2022. This is the largest percentage increase noted in the study, indicating a growing commitment to sustainable practices among businesses in Ireland. Sustainability efforts and industry leadership The findings suggest that progress is being made, with 74 percent of respondents rating their sustainability efforts as 'established or better', up from 61 percent in 2022. Fifteen percent consider their efforts 'industry-leading', meanwhile, doubling the corresponding seven percent recorded in 2022. There is still room for improvement, however, with 35 percent of this year’s respondents noting their organisation is not doing enough, up significantly from 17 percent in 2022. Fear of greenwashing influences communication strategies Awareness of the negative impact and reputational risk associated with misleading sustainability claims is growing. Thirty-five percent of the respondents in the EY State of Sustainability 2024 report indicated that fear of greenwashing is influencing their communication strategies, a significant increase from 13 percent in 2022. Key motivations for sustainability Rising stakeholder interest, regulations and perceived bottom-line benefits are key motivating factors driving sustainability in organisations. Close to two-thirds (65%) of businesses reported wider stakeholder enquiries about sustainability impact, up from 49 percent in 2022. More than half (58%) believe demonstrating a greater commitment to sustainability is necessary for access to capital. Interestingly, 30 percent indicated they are increasingly assessing the sustainability status of target companies when considering a merger or acquisition. Regulatory concerns Navigating complex EU regulations is the leading sustainability-related concern for organisations, according to EY’s research, with the EU Emissions Trading System cited by almost two-thirds (65%) as a key concern. Supply chain due diligence, driven by the Corporate Sustainability Due Diligence Directive (CSDDD), is a concern for 62 percent of respondents. The EU Deforestation Regulation and plastic packaging-related measures were cited by 54 percent and 46 percent of respondents, respectively. Supply chain responsibility Sustainability regulations such as the Corporate Sustainability Reporting Directive (CSRD) and CSDDD are designed to make organisations more sustainable by holding them accountable for their supply chains. Sixty-two percent of respondents cited supply chain due diligence as their biggest sustainability-related concern. Engagement levels with supply chains on ESG reporting vary, with 26 percent having not engaged at all, while 50 percent have technology solutions in place to gather data for compliance purposes. Long-term resilience The findings show that the link between sustainability and profitability is becoming an increasingly important factor in corporate strategies. As companies embrace this agenda, they must engage with all stakeholders to create a more resilient and sustainable business. Irish businesses are moving toward sustainability, with growing stakeholder interest, regulatory pressure and bottom-line benefits driving this shift. The report shows that more companies are embedding sustainable practices. Despite this, concerns about greenwashing and regulatory compliance remain challenging. Notably, many companies are scrutinising the sustainability of potential mergers and acquisitions, signalling a commitment to change. While progress is evident, there is still work to do, especially in supply chain accountability. For sustained impact, continued engagement with stakeholders and a proactive approach to regulation will be essential for long-term resilience. Derarca Dennis is Assurance Partner and Sustainability Services Lead at EY

Get in touch with your Chartered Accountants Ireland Careers Team today to help sculpt your new CV now that you are qualified. Its never too early to start this essential document. We will send you a template to get you started and you can schedule an online call to review and talk through it once complete.   For the moment, here are some initial CV tips, pitfalls, versions and suggestions : Minimise (no) colour No photo – that’s more a continental thing. Your latest job detail should take up about half of the 1st page – good detailed points. Use ‘ownership’ terminology such as “I drove, I led, I resolved … “ 1 or 2 lines about your current employer = context Use the width of the page- no large whitespace gaps | Typically 2 full pages give or take. Ariel or Calibri 11 or 12 Include your Annual Review Rating if you got a good one. Naming Clients – where suitable … to give context. Clients : - what size / what sector ? Have a few versions of your cv for different applications Include Academic results 2.1 / 2.2 / 510 points 3.8 grade avg etc Punchy – Not long winded story style points. Profile Summary for HR/Website applications – per below Strong References available on request(include of you have) Include Charity work, societies, events, articles written etc. Spelling – check it and triple check it Focus on the getting across your competencies and your value add Identify your USP / What differentiates you System Skills ? ( Tip )  Create a Summary profile or synopsis to go alongside your CV or to be mailed with your cv attached to either recruiters or employers : For example :  My Profile Summary : ACA 2022 Big 4 Trained – Audit Currently in XYZ plc as a Financial Accountant Previously Audit Senior working with Banking Insurance and Funds clients Very strong leadership qualities and relationship building track record Strong audit fundamentals Very keen on a move into IA with the right organisation and ABC ltd very much appeals. Excellent communication skills and very positive client interaction feedback 100% comfortable with travel required On 55k base + solid bens currently Target base 60/65k base circa Linkedin Profile : https://www.linkedin.com/in/daveriordanaca/ Get in touch with your Careers Team in the Institute as your first step once you qualify for cv, interview and market guidance as well as job placement and an unbiased, objective view of the market and your career path.  Dave Riordan (ACA) Recruitment Specialist & Career Coach | Careers Team Chartered Accountants Ireland. Dave.riordan@charteredaccountants.ie   

The Failure to Prevent Fraud offence was introduced in section 199 of the Economic Crime and Corporate Transparency Act 2023 (ECCTA). The Act provides that the Secretary of State must issue guidance about procedures before the provisions come into force. This guidance to organisations on the offence of failure to prevent fraud has now been issued (as  of 6 ,November 2024). The guidance states that the offence will come into effect nine months after the publication of this guidance, to allow organisations to develop and implement their fraud prevention procedures. A reminder of what the Failure to Prevent Fraud offence is. The legislation will apply to large organisations where an associate of the organisation commits any of the offences listed in schedule 13 of the ECCTA (for example, cheating the public revenue or false accounting) with the intention of benefitting the organisation and the organisation did not have in place reasonable fraud prevention procedures. The large organisations to which the legislation will apply align with the thresholds in the Companies Act 2006. In short, a large organisation is one satisfying two or more of the following conditions: turnover of more than £36 million; balance sheet total of more than £18 million; or more than 250 employees. Readers should be mindful that there are proposals to uplift the monetary thresholds under company law. 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 Sept 2024 the UK government announced the launch the Office of Trade Sanctions Implementation (OTSI), within the Department for Business and Trade. Click here also for further information. To equip the office with new civil enforcement powers, on 12 September 2024, the UK government passed the Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024. Click for the explanatory memorandum. OTSI’s enforcement powers came into effect from 10 October 2024. They apply to all UK persons including businesses wherever they are in the world and any person including businesses in the UK or the UK territorial sea. The regulations introduce new civil enforcement powers, including the power to impose monetary penalties, for breaches of aircraft, shipping and certain trade sanctions. The regulations also give the Secretary of State the option to publish reports where a breach of sanctions regulations has occurred. Click for statutory guidance on the Trade, aircraft and shipping sanctions, civil enforcement. 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.    

A revised IGP approved by JIC and each of the Recognised Professional Bodies (RPBs) relating to the control of cases has been issued by each of the RPBs. Introduction of the revised Insolvency Guidance Paper – Control of Cases

Last week’s Autumn Budget and the first for new Chancellor of the Exchequer Rachel Reeves featured £40 billion in tax rises and was announced with the objective of repairing public finances because of £22 billion of “in-year pressures” whilst at the same time establishing a robust foundation for economic growth. However, the April 2025 changes in employer National Insurance Contributions (NICs) will increase the cost of employment for many businesses when combined with the increase in the national minimum and living wage. Smaller employers will be somewhat protected as a result of changes from the same date to the employer NICs employment allowance. The rates of capital gains tax were also increased from Budget Day with the Office for Budget Responsibility (OBR) estimating that this will raise an additional £2.5 billion. And buried in the Budget publications was the news that Making Tax Digital (MTD) for income tax will be extended to unincorporated businesses and landlords with turnover over £20,000 by the end of the current Parliament the precise timing for which will be set out at a future fiscal event. Chartered Accountants Ireland will be challenging the Government on this reduction in the MTD exemption limit. A range of changes to inheritance tax (IHT) were also announced with the aim of ensuring that the wealthiest estates will bear the greatest burden with the scope of agricultural and business property relief to be limited and the news that unused pension funds and death benefits payable from a pension into a person’s estate will be within the scope of IHT in future. The rate of stamp duty land tax on acquisitions of certain residential property in England and Northern Ireland was also increased from 31 October 2024. On the business side, the publication of the previously announced Corporate Tax Roadmap should provide businesses with more certainty and once again confirms that no changes will be made to the current rates of corporation tax, amongst other business taxes areas. The UK’s CT rate is currently the lowest in the G7. A response was also published to the consultation on potential regulation of tax advisers which the Institute responded to earlier this year. The consultation response sets out that from April 2026 the Government will mandate registration of tax advisers who interact with HMRC on behalf of clients. A further consultation will also be published on tackling rogue tax advisers. However, the consultation response is silent on any new measures to regulate the UK tax agent market. HMRC has sent a more detailed email setting out information on the consultation response and is planning a round table meeting later this month to discuss the way forward in more detail. Chartered Accountants Ireland will be in attendance. And finally, the Northern Ireland Executive will receive an additional £1.5 billion in funding in 2025/26 through the operation of the Barnett formula. Read the Institute’s Press Release reacting to the Autumn Budget 2024. The analysis herein is based on the publications of HMRC and HM Treasury. A more detailed analysis of the tax announcements features in the remainder of today’s UK section and will continue in next Monday’s edition of Chartered Accountants Tax News. The Institute’s UK Autumn Budget 2024 page also contains a range of resources. HMRC has also sent an email on the Budget announcements and one specifically for agents. An overview of all the tax legislation and rates announced has also been published.

Some capital gains tax (CGT) rates were increased from Budget Day and the rate of both Business Asset Disposal Relief (BADR), and Investors’ Relief (IR) will be increased in two stages starting from April 2025. A range of significant changes will also be made to inheritance tax (IHT) which will see IHT extended to death benefits payable from a pension into a deceased’s estate, in addition to changes to both business property relief (BPR) and agricultural property relief (APR). Previously announced changes, including the abolition of the CGT and income tax non-domicile regime from 6 April 2025 which will be replaced with a new residence-based regime, were also confirmed.  The territoriality of IHT will also move to a residence-based regime as planned. CGT rate increases For disposals made on or after 30 October 2024, the lower rate of CGT increased from 10 percent to 18 percent, whilst the higher rate increased from 20 percent to 24 percent.  These new rates align with the residential property CGT rates which remain unchanged. Carried interest is a performance-related reward received by a small population of fund management executives. From April 2026, carried interest will be taxed fully within the income tax framework, with bespoke rules to reflect its unique characteristics and a 72.5 percent multiplier applied to qualifying carried interest that is brought within charge. As an interim step, the two CGT rates for carried interest will both increase to 32 percent from 6 April 2025. The Government will also consult on introducing further conditions of access into the regime. CGT BADR and IR As a result of the newly increased rates of CGT, BADR and IR will both increase from 10 percent to 14 percent from 6 April 2025 and to 18 percent from 6 April 2026 to allow business owners time to adjust to the changes. The lifetime limit (LL) for BADR will remain at £1 million. In contrast, the LL for IR reduced from £10 million to £1 million for all qualifying disposals made on or after 30 October 2024. Chartered Accountants Ireland has previously questioned the policy need for IR and its high lifetime limit. The Government has also stated that it is committed to creating a positive environment for entrepreneurship and will work with leading entrepreneurs and venture capital firms on how policy supports that, including the role of existing tax schemes. A commitment was also made to make it easier for start‑ups and scale‑ups to access external sources of financial support. This includes, as already legislated for, extending the Enterprise Investment Scheme and Venture Capital Trust schemes to 2035. Non-UK domiciled status As previously announced, the non-UK domiciled regime, and thus the remittance basis of taxation for CGT and income tax, is being abolished from 6 April 2025. The remittance basis will be replaced with a residence-based regime. Individuals who opt-in to the regime will not pay UK tax on foreign income and gains (FIG) for the first four years of tax residence. Current and past remittance basis users will be able to rebase personally held foreign assets to the assets 5 April 2017 market value on a disposal, subject to certain conditions. Overseas Workday Relief will be retained and reformed, with the relief extended to a four-year period and the need to keep the income offshore removed. The amount claimed annually will be limited to the lower of £300,000 or 30 percent of the employee’s net employment income. The Temporary Repatriation Facility (TRF) is being extended from two to three years until 5 April 2028, expanding the scope to offshore structures, and simplifying the mixed fund rules to encourage individuals to spend and invest their FIG in the UK. The TRF will enable the individual to designate and remit at a reduced rate of tax any foreign income and gains which arose prior to 6 April 2025. This includes unattributed foreign income and gains held within trust structures IHT measures and reliefs IHT thresholds (£325,000 nil rate band, £175,000 residence nil rate band, and the £2 million residence nil rate band taper) will remain frozen at their current levels for a further two years beyond April 2028 until April 2030. Significant reforms to both APR and BPR were also announced. From April 2026, the first £1 million of combined qualifying agricultural and business assets will be entitled to 100 percent relief from IHT with the rate of relief reduced to 50 percent for amounts in excess of £1 million. The rate of BPR will also be reduced to 50 percent for shares designated as “not listed” on the markets of a recognised stock exchange, such as AIM. However, from 6 April 2025 the scope of APR will be extended to land managed under an environmental agreement with, or on behalf of, the UK government, devolved governments, public bodies, local authorities, or approved responsible bodies. As previously announced, the new IHT residence-based regime will commence from 6 April 2025. This includes ending the use of offshore trusts to shelter assets from IHT and scrapping the planned 50 percent tax reduction for foreign income in the first year of the new regime. From 6 April 2027 unused pension funds and death benefits payable from a pension into a person’s estate will be subject to IHT purposes. In doing so the Government aims to restore the principle that pensions should not be a vehicle for the accumulation of capital sums for the purposes of inheritance. £52 million is also being invested to digitalise the IHT service from 2027/28 with the aim of providing a modern, easy-to-use system for making returns and paying IHT.

It was again confirmed that there will not be any increases in the basic, higher, or additional rates of income tax, or employee National Insurance Contributions (NICs). The freeze on certain personal tax thresholds will also end from 6 April 2028. The treatment of some double cab pick-ups will change from vans to cars and the proposed household income system to assess the high-income child benefit charge will not proceed. Some tax thresholds to be defrosted The freeze on the income tax and employee national insurance thresholds will not be extended beyond 2027/28, meaning that from 2028/29 taxpayers can expect the thresholds to again begin to increase in line with inflation. However, as many of these thresholds will have been frozen since 2020/21, fiscal drag means that the tax burden has and will continue to rise because there have not been any inflationary increases. From 6 April 2025, the employee NICs Lower Earnings Limit (LEL) and the Small Profits Threshold (SPT) will both increase by the September 2024 CPI rate of 1.7 percent. The LEL will be £6,500 per annum (£125 per week) and the SPT will be £6,845 per annum. For those paying voluntarily, Class 2 and Class 3 NICs rates will increase from the same date by the same amount. The main Class 2 rate will be £3.50 per week, and the Class 3 rate will be £17.75 per week. Double cab pick-up vehicles to be treated as cars Following a Court of Appeal judgement, double cab pick-up vehicles (DCPUs) with a payload of one tonne or more will be treated as cars for certain tax purposes. The previous Government had planned to do so from 1 July 2024 as announced last February but did a U-turn on this after representations from industry. From 1 April 2025 for Corporation Tax, and from 6 April 2025 for Income Tax, DCPUs will be treated as cars for the purposes of capital allowances, benefits in kind, and some deductions from business profits. The existing capital allowances treatment will apply to those who purchase DCPUs before 6 April 2025. Transitional benefit in kind arrangements will apply for employers that have purchased, leased, or ordered a DCPU before 6 April 2025. They will be able to use the previous treatment, until the earlier of disposal, lease expiry, or 5 April 2029. High Income Child Benefit Charge (HICBC) reform to household income not proceeding The Government will not proceed with the reform announced in the Spring Budget 2024 to base the HICBC on household income. According to the Budget publications, this is because it would have come at a significant fiscal cost of £1.4 billion by 2029/30. However, to make it easier for all taxpayers to get their HICBC right, employed individuals will be able to pay the HICBC through their tax code from 6 April 2025, and Self-Assessment returns will be pre-prepopulated with Child Benefit data for those not able to do so. Starting rate for savings unchanged This will remain unchanged in 2025/26 at £5,000 and although this will allow individuals with less than £17,570 in employment or pensions income to receive up to £5,000 of savings income tax free, this does not take into account higher interest rates on savings income in recent years. Taxable status of Statutory Neonatal Care Pay The Government will legislate in Finance Bill 2024/25 to clarify the income tax treatment of Statutory Neonatal Care Pay which will ensure the payment is liable to income tax to ensure consistency with the tax treatment of other statutory maternity and paternity pay schemes. Employment related securities changes From 6 April 2025, the notice an employer must provide to an employee under a Share Incentive Plan regarding the possible effect of deductions from salary on entitlement to social security benefits and statutory payments must refer to statutory neonatal care pay. This will be legislated for in Finance Bill 2024/25. Further loan charge review to be commissioned A further independent review of the loan charge will be commissioned to help bring the matter to a close for those affected, whilst ensuring fairness for all taxpayers. Further details about the review will be set out by the Exchequer Secretary in due course.  Company car tax (CCT) rates for 2028/29 and 2029/30 announced The Government announced the rates for CCT for these tax years. CCT rates will continue to strongly incentivise the take-up of electric vehicles, while rates for hybrid vehicles will be increased to align more closely with rates for internal combustion engine vehicles in order to focus support on electric vehicles. The changes are as follows: Appropriate Percentages (APs) for zero emission and electric vehicles will increase by 2 percentage points per year in 2028/29 and 2029/30, rising to an AP of 9 percent in 2029/30. APs for cars with emissions of 1 – 50 g of CO2 per kilometre, including hybrid vehicles, will rise to 18 percent in 2028/29 and 19 percent in 2029/30. APs for all other vehicle bands will increase by 1 percentage point per year in 2028/29 and 2029/30. The maximum AP will also increase by 1 percentage point per year to 38 percent for 2028/29 and 39 percent for 2029/30. This means for vehicle bands with emissions of 51 g of CO2 per kilometre and over, APs will increase to 19 percent – 38 percent in 2028/29 and 20 percent – 39 percent in 2029/30. Qualifying care relief From 6 April 2025, qualifying care relief, the amount of income tax relief available to foster carers and shared lives carers will increase by the September 2024 CPI rate of 1.7 percent.