Tackling systemic hurdles to the long-term economic health of Ireland’s SMEs will be a top priority for Barry Doyle, the new President of Chartered Accountants Ireland. As Investment Director with MASV, the entrepreneur-led investment firm, Doyle brings considerable experience in advising and scaling successful businesses. He took up the office of President on Friday, 17 May, following the Institute’s 136th AGM. At just 37, Doyle is the youngest President in the Institute’s 136-year history, but already he has gained deep expertise in the start-up environment in Ireland and overseas and continues to work with scaling businesses from their earliest stages through growth and exit. The need to support and champion these businesses is a cause close to his heart. “I’ve worked mainly with start-ups and early-stage companies throughout my career,” Doyle says. “I’m drawn to entrepreneurs – for me, it’s about building something from scratch and seeing it gain traction, grow and succeed. It excites me. The start-up environment can be tough but it is also incredibly rewarding.” In his role with MASV, Doyle supports ambitious start-ups scaling internationally. “I’ve gone from working in hands-on roles within these businesses to now guiding them as a board director, observer and advisor and investing in people’s ideas at MASV,” he says. “I really enjoy it. There is a lot of variety in working with international companies of different sizes and at different stages of development.” Shining a spotlight on SMEs During his term as President, Doyle is keen to focus on those members of the profession who own, support and advise Ireland’s SMEs in both the North and south. “Many of our members run SMEs. We have practitioners out there running their own businesses the length and breadth of the country,” he says. “Not only do they support other SMEs in their day-to-day work, but they are also business owners and entrepreneurs themselves. “They provide employment, often in regional towns and cities. It is important to me that we shine a light on the value these members are providing every day.” Although he believes Ireland offers a broadly supportive environment in which start-ups and SMEs can flourish, Doyle is also acutely aware of the challenges facing this crucial cohort of the Irish economy. “Record corporation tax receipts will not always be with us. There’s a strategic imperative to ensure economic health for SMEs long-term,” he says. Doyle believes this can only come from understanding the unique challenges they face, not simply by virtue of their size, but also related to the sector they operate in – and the supports they need. “We need to be very mindful of new initiatives that are being rolled out, such as pension auto-enrolment, increasing the minimum wage and PRSI costs, so we can ensure that they don’t give rise to prohibitive costs for business.” SMEs are also being impacted by wider infrastructural issues that must be addressed, such as the availability of both housing and childcare, Doyle warns. “The cost of doing business and these infrastructure issues are intrinsically linked and need to be considered in totality,” he says. “The question is: what can we reasonably expect businesses to cope with?” Blueprint for sustained growth Chartered Accountants Ireland has published a new thought leadership paper setting out measures to help achieve strategic, systemic improvements for SMEs in Ireland. These measures include: Further increases to the thresholds for Employer PRSI so all wages up to the minimum wage are exempt and wages up to the living wage are at the reduced rate of 8.8 percent. No extension to the Enhanced Reporting Requirements (ERR) for at least three years and not before an appropriate cost-benefit analysis of the current system has been completed. Reducing Capital Gains Tax from 33 percent to 25 percent to stimulate business and personal transactions that will bring additional funds into the Exchequer. Wider SME eligibility for grants to include more ‘traditional’ industries and the service sector. A more prominent role for the Strategic Banking Corporation of Ireland in encouraging banks to provide low-cost credit to SMEs, and to underwrite this credit. New opportunities for Credit Unions to increase SME lending by adapting Central Bank regulations – e.g. lending limits. Curbing high business costs “Broadly speaking, I think Ireland is pro-business and pro-entrepreneurship, but there are challenges. The cost of doing business in Ireland is rising and this is becoming quite a big issue for SMEs,” Doyle says. Chartered Accountants have first-hand experience of the cost and administrative burdens SMEs are encountering, Doyle adds, and the proposals outlined in the Institute’s new thought leadership paper are tailored to address these. The publication of the paper followed extensive engagement with members, two-thirds of whom work in business. “Government commitment to the SME sector in Budget 2025 is welcome, but this is a commitment that will need to endure even as we move towards a new Government next year,” Doyle says. “Our thought leadership paper offers a blueprint that in the long-term will effect change if implemented. We must ensure that a strategic lens is adopted in tackling what are stubborn, systemic hurdles for SMEs.” Successful career path Originally from Rosslare, Co. Wexford, Doyle studied accounting and finance at Dublin City University, interning with EY Ireland’s tax and audit divisions in his second year of studies. After graduating in 2006, he returned to EY to train in assurance and went on to join the National Geographic Channel in Sydney. He was Regional Finance Manager for National Geographic Channel in Australia and New Zealand for two years as it expanded to become Fox International Channels. In 2013, after returning to Ireland, Doyle joined Storyful in the role of Chief Financial Officer. The online news and content verification company founded by former journalist Mark Little was acquired in 2013 by News Corp for a reported $25 million. Doyle then went on to work with e-commerce start-up xSellco for two years, again in the role of CFO, followed by a two-year stint as Chief Operating Officer with recruitment firm Mason Alexander. He joined MASV in 2020 shortly after the entrepreneur-led investment firm had been established by Dan and Linda Kiely who sold Voxpro, their business process outsourcing firm, to Canadian company Telus International in 2017. Doyle is also currently a Director of Republic of Work and Board Observer for both OpenforVintage and Johnson Hana. “I think my own career is testament to the sheer range of roles open to Chartered Accountants – and to how far your qualification and training can take you from a relatively early stage,” he says. “The knowledge you have means you can add value from the get-go and this can propel your career along a very exciting path.” Vibrancy and diversity of profession During his year as President of Chartered Accountants Ireland, Doyle is keen to shine a spotlight on these opportunities and the vibrancy and diversity of a profession that continues to play such an integral role in all sectors on the island of Ireland and overseas. “It’s really important that we highlight the many opportunities our profession offers globally, but also increasingly here in Ireland. Every single business and organisation has an accountant at the heart of their decision-making,” he says. This reach means that the profession is also inherently valuable to the economy, as demonstrated by research carried out recently by Oxford Economics. A report published by Oxford Economics in January on behalf of the Consultative Committee of Accountancy Bodies, found that the Irish accountancy profession – comprising the accountancy sector and accountants working across the wider economy – contributed €19.8 billion to the Irish economy in 2022. The report further found that the profession generated €1.8 billion in tax revenues in 2022. In Ireland and Britain combined, the profession contributed €114 billion to both economies in 2022, generating €13.7 billion in tax revenues. Behind these headline figures, there are over 83,000 individuals employed by the accountancy profession in Ireland, driving and servicing business in all sectors. “One of our USPs as Chartered Accountants is the high ethical standard we are held to as professionals,” Doyle says. “People look to us as trusted advisors. We act in the public interest and I think this is very important in terms of driving the economy towards sustained growth in a well-thought out manner.” Engaging with members at grassroots In addition to championing and supporting SMEs, Doyle is keen to engage with as many members as possible at grassroots level at a time when membership is set to swell from 33,000 to 38,000. Members of Chartered Accountants Ireland and CPA Ireland voted in favour of a proposal to amalgamate the two Institutes earlier this year. This will see the creation of a single Institute, named Chartered Accountants Ireland, which will be the largest professional body on the island of Ireland. The proposal was endorsed by the Councils of both Institutes who believe it will better position the profession for the future, driving new growth opportunities while also being stronger to meet challenges. “As the Institute grows, it is more important than ever that what we offer is relevant to as many of our members as possible – and that it speaks to the reality of their professional lives, needs and priorities,” Doyle says. “The Institute exists to support and elevate the profession, to uphold our professional standards in the public interest and to continue to educate members and future members. Ultimately, everything we do begins and ends with our members.” Doyle has served as Deputy President of the Institute for the past year, supporting outgoing President Sinead Donovan alongside Vice (now Deputy) President Pamela McCreedy. “Sinead is an inspiration to so many and a fantastic leader,” he says. “I will be continuing her focus on the future of the profession and our ‘next gen’ during my own term as President and also picking up on our predecessor Pat O’Neill’s very valuable work during his time as President in calling for reform of the Leaving Cert accounting syllabus.” The power of connection Doyle has been a member of the Council of Chartered Accountants Ireland since 2015 and has chaired the Institute’s Digital Steering Group and Members Board as well as the Members in Business and Strategic Communications Committees. “I made the decision to go for Council when I was just 27. It goes back to my time in Australia and the power of the Australian society and sense of community I found there,” he explains. “We came together as Chartered Accountants and I always knew that there was a group there to support me. That sense of connection is really powerful when you’re so far away from home. “It’s not lost on me that I will be the youngest President in the history of the Institute, but I think that’s a good thing. “Sixty percent of our membership is now aged 44 and below. The profile of our membership is changing and I think it matters that our members can see this represented on our Council.”

Do you use HMRC online services? Don’t be caught out by the planned downtime to some services. HMRC are warning about the non-availability of specific services on the HMRC website, a range of services are impacted. Check the relevant page for information on planned downtime.  

At the most recent meeting of the Inclusive Framework on Base Erosion and Profit-Shifting, the OECD Secretary-General Mathias Cormann welcomed the commitment of the group to resolve the outstanding issues with Amount A of Pillar One which should enable the signing of the Multilateral Convention implementing the rule by the end of June 2024. The key concern is reaching agreement on a fair allocation of taxing rights across the 147 countries who make up the Inclusive Framework.

Revenue has published a new manual on the Flat-rate Farmers Refund Order. The new guidance outlines how VAT can be reclaimed, with commentary on the necessary conditions, the types of expenditure and information required to make a claim.

Readers may be aware of a minor update to the guidance on relief for investment in corporate trades (including the Employment Investment Incentive Scheme (EIIS)), whereby the date on the face of the Tax and Duty Manual (TDM) was changed from April 2023 to May 2024. This has caused some confusion as there had been no updates to the contents of the manual since the April 2023 release. Revenue has provided an update to the Institute through the TALC Direct & Capital Taxes Sub-committee confirming that the TDM is presently being updated to reflect the changes implemented by Finance (No. 2) Act 2023. Revenue’s update is as follows: “In the course of the last meeting of the TALC Direct and Capital Taxes Sub-Committee and subsequently, queries were raised regarding the updating of TDM Part 16-00-02 “Relief for Investment in Corporate Trades” and initial risk finance investment.    We wish to advise that the matter which delayed publication of the update of TDM Part 16-00-02 “Relief for in investment in corporate trades” is still under consideration and it remains the intention to circulate a draft of the updated TDM prior to publication as soon as we are in a position to do so.  We note that a version of the TDM was recently published on www.revenue.ie stating that it was last reviewed in May 2024.  This was an error that arose whereby the retention of the TDM last reviewed in April 2023 was extended which resulted in an incorrect date on the first page.  This has been rectified and we confirm that no changes have been made to the TDM.  We regret any confusion caused.   In relation to the queries raised on initial risk finance, and in light of the delay in publication of the TDM, please note the following clarification.   We wish to confirm that it remains possible to raise initial risk finance investment in tranches as has always been the case.  The position is unchanged from that as set out in the TDM which states “Many companies who seek to raise EII, SCI or SURE supported funding, do so in tranches. That is, they embark on a fundraising round over a number of months. Shares are usually issued at the end of the fundraising round, but there may be occasions where the shares are issued as the amounts are invested. The initial risk finance investment will be the initial round of fund raising, whether the shares are issued at the end, or throughout that fundraising round. It should be noted that the shares should be fully paid up at all times throughout the relevant period.”  The initial risk finance investment requirements must be set out in the business plan in line with the legislative requirements in that regard and as specified in the TDM.  Where a business plan identifies a need for State aid in the form of initial risk finance and those funds are subsequently raised in tranches, each tranche will form part of the initial risk finance investment and will not constitute follow-on investment until the initial risk finance investment as provided for in the business plan has been raised.    Where an investment is raised in tranches, it should be noted that the rate of relief that may be availed of on investment could differ over the course of an extended period i.e. a company may be part of a RICT group that is not operating in any market at the time of one tranche of investment and it may be a company that is part of a RICT group operating in a market at the date of a later investment tranche. The rate of relief to apply to the investment will depend on whether the company is part of a RICT group that is not operating in any market or part of a RICT group that is operating for less than 10 years post incorporation or less than 7 years following its first commercial sale at the time the eligible shares are issued in line with section 496(5) TCA.  For shares issued on or after 1 January 2024, the amount of a qualifying investment that may qualify for relief is as follows: In the case of initial risk finance investment in a RICT group which has not been operating in any market, pursuant to section 496(5), 125% of the investment may qualify for relief giving rise to a rate of relief of up to 50%. In the case of initial risk finance investment in a RICT group which has been operating in any market for less than 10 years post incorporation or less than 7 years following its first commercial sale, pursuant to section 496(5), 87.5% of the investment may qualify for relief giving rise to a rate of relief of up to 35%. In the case of expansion risk finance investment pursuant to section 496(6), 50% of the investment may qualify for relief giving rise to a rate of relief of up to 20%. In the case of follow-on risk finance investment pursuant to section 496(7), 50% of the investment may qualify for relief giving rise to a rate of relief of up to 20%. In the case of investments made indirectly via a qualifying investment fund, 75% of the investment may qualify for relief giving rise to a rate of relief of up to 30%. Accordingly, in the case of a company that is raising its initial risk finance investment in tranches throughout 2024 where it is part of a RICT group that makes its first commercial sale on 1 June 2024 for example, the rate of relief will be up to 50% where the eligible shares are issued prior to 1 June 2024 and it will be up to 35% where the eligible shares are issued on or after 1 June 2024.”

The Institute is represented on two HMRC VAT forums; the Joint Vat Consultative Committee (“JVCC”) and the VAT Registration Sub-Group forum. Recent updates from each are set out below. JVCC update   The JVCC is an HMRC forum to exchange views between HMRC and representative bodies and other organisations relating to the procedures and operations of VAT, and to consider and discuss VAT issues arising from member organisations with the aim of strengthening HMRC’s understanding of the needs of the business/taxpayer. The minutes from the 125th JVCC meeting have been published and are available on GOV.UK.   The JVCC has also been advised that the new VAT Tertiary Legislation manual is now available. Except for margin scheme content, nothing in the manual new as it has all been published previously on GOV.UK. The revised margin scheme tertiary legislation is available in the manual for the first time following the withdrawal of VAT Notice 718.  To date, HMRC has not removed any force of law content from VAT Notices and so, much of it is duplicated in both this manual and its original home on GOV.UK. In due course, HMRC aims to remove legal content from its VAT Notices and replace it with plain English, where appropriate.  In the new manual, HMRC has aimed to maintain a logical structure and has included heading numbers for ease of reference. As the manual is new, HMRC is seeking feedback using the buttons in the manual.   VAT registration Sub-Group forum  Details of action points and HMRC responses from the January 2024 meeting of this forum are set out below.  A member asked whether the guidance made it clear that customers might need multiple authorisations for VAT.   This has been investigated and a change to the wording of the guidance was required and has been instigated. The guidance will be updated.  Can the VAT50 and VAT51 forms be uploaded and added to the application at the end of the online VAT registration process?  The VAT 50/51 can be either attached at the point of submission of the VAT registration within the digital journey, or taxpayers can choose to send this to HMRC via post. HMRC’s preference is that these forms are uploaded via the Vat Registration Service (“VRS”) if the taxpayer or their agent is able to do so.  Can a review be carried out regarding virtual offices and the principal place of business?  A review has been instigated and is currently ongoing. Details will be shared when an update is available.  Were specified supplies included when the previous review was carried out on compulsory registration?  HMRC has updated the rules behind the VRS to take account of these. When a person applying under these circumstances enters the words ‘SPECIFIED SUPPLIES’ in the ‘Business Descriptions’ free text box, the application will not be rejected.  HMRC has updated section 2.7 of VAT Notice 700/1 to this effect and is considering the most appropriate place to include an update in the VRS itself to best support applications.   Does the registration team no longer send out confirmation of registration changes?  VAT registration and variation outputs are generated automatically and issued to the taxpayer when the application or variation has been processed; there is no manual process to issue an output to provide the same confirmation.  Other updates  HMRC provided an update regarding queries that have been made in relation to Parish Councils and Public Bodies as follows:-  “Applications for VAT registration from public bodies should be made on a paper VAT1 as per current guidance. When we can introduce a bespoke journey into the online VAT Registration Service, we will communicate this via the appropriate channels, but there are currently no plans for this.” 

Better long-term support for the SME sector was advocated for by Director of Advocacy and Voice, Cróna Clohisey, and Institute President Barry Doyle who both represented Chartered Accountants Ireland at the National Economic Dialogue (NED) last week. The NED provides a forum for public consultation and debate ahead of Budget 2025 and this year’s theme was challenges and opportunities in a more shock-prone world. The Institute representatives also emphasised to Ministers the importance of careful consideration around the timing of new regulations and their impact on businesses, the need to simplify the tax system, in addition to enhancing the supply of childcare places. Documents and speeches from the NED can be found on gov.ie.

In its response to the consultation “Raising standards in the tax advice market – strengthening the regulatory framework and improving registration” which examined three different approaches to regulate the UK tax agent market in future, the Institute’s Northern Ireland Tax Committee sets out that its preferred approach is mandatory membership of a recognised Professional Body. However, the Committee also tells HMRC that additional regulation of practising members of Chartered Accountants Ireland is not needed. The Committee’s full response can be read in the Tax Representations section of our website.  The Committee also recommended that there should be a minimum transition period of not less than five years to ensure that the change is properly implemented, and the market is able to fully prepare and adjust. It is also recommended that HMRC consider what transitional arrangements can be introduced once a decision has been made on the approach to be taken.  

The Spring Finance Bill 2024 (official title Finance (No. 2) Bill 2023-24), which reflects many of the tax measures announced as part of the Spring Budget, received Royal Assent last Tuesday 28 May just before Parliament was dissolved on 30 May. Finance (No.2) Act 2024 now has force of law as Royal Assent is the final stage of a bill's passage through Parliament.   Some of the measures included in the Act are as follows:-  the higher rate of capital gains tax on disposals of residential properties is reduced from 28 percent to 24 percent for disposals from 6 April 2024;   the thresholds for the high income child benefit charge increased from 2024/25 onwards from £50,000 to £60,000 (lower threshold) and £60,000 to £80,000 (higher threshold); and  multiple dwellings relief for stamp duty land tax is abolished where the effective date falls on or after 1 June 2024. This change is subject to transitional arrangements. 

In this week’s EU exit corner, we bring you the latest guidance updates and publications relevant to EU exit. The most recent Trader Support Service bulletin is also available. And finally, we issue a final reminder that from today, Tuesday 4 June 2024, all export declarations must be made via the Customs Declarations Service, and not CHIEF.  Miscellaneous updated guidance etc.   Recently updated guidance, and publications relevant to EU exit are set out below:-  UK Trade Tariff: European Union and new member states;  UK Trade Tariff: preferential trade arrangements for countries outside the UK and EU;  UK Trade Tariff: relief from customs and excise duties and VAT;  UK Trade Tariff: end-use relief on goods used for a prescribed use;  UK Trade Tariff: VAT;  UK Trade Tariff: valuing goods;  UK Trade Tariff: appeals;  Managing your customs warehouse; and  Notices made under the Taxation (Cross-border Trade) Act 2018. 

Check out the latest items on the Agent Forum. Remember, in order to view each item, you must be signed up and logged in.   All agents, who are a member of a professional body, are invited to join HMRC’s Agent Forum. This dedicated Agent Forum is hosted in a private area within the HMRC’s Online Taxpayer Forum. You can interact with other agents and HMRC experts to discuss topical issues and processes. 

Technical Alert 02/2024 – Sample Engagement Letter Terms in respect to the provision of Limited Assurance under the Corporate Sustainability Reporting Directive A Technical Alert (TA) has been issued to provide assistance to members when drafting engagement letters in respect to limited assurance engagements under the Corporate Sustainability Reporting Directive (“CSRD”) which has yet to be transposed into Irish legislation. Until this transposition occurs (expected July 2024), in the interim and to allow engagement planning to commence, these engagement letter terms may be used to implement a formal contract with the entity. Addendums and/or replacement engagement letter terms may be required where significant changes are necessary; members are advised to note the important caveats in the preface to this TA. The engagement letter terms have been drafted based on current guidance in issue which may change as the CSRD regulatory landscape changes. In addition the applicable standard used is the International Standard on Assurance Engagements (ISAE) 3000 (Revised) issued by the International Auditing and Assurance Standards Board (IAASB). This may be subject to change, depending on the assurance standard that is specified for use in Ireland for CSRD sustainability assurance engagements by the Irish Auditing and Accounting Supervisory Authority (IAASA). You can access the TA here.

The Financial Reporting Council (FRC) has published anonymised key findings and good practices reported by its Audit Quality Review (AQR) team in relation to their 2020/21 audit quality inspections at the seven largest audit firms. https://frc.org.uk/news/may-2022-(1)/frc-publishes-inspection-key-findings-and-good-(1)

Just 17% of Chartered Accountants in Northern Ireland believe that prospects for the NI economy in 2024 are good with over half (59%) seeing the economy as either stagnant or slowing, according to the Institute’s latest Financial Confidence Survey. Feedback from members working in business, practice and across the public sector have cited ongoing skills shortages, rising inflation and cutbacks in government spending as contributing to this dampened outlook. On a more positive note, an overwhelming majority of members (87%) view the dual-market access afforded to Northern Ireland post-Brexit as its biggest opportunity for growth over the next decade. Chartered Accountants Ulster Society is a district society of Chartered Accountants Ireland, Ireland’s oldest and largest professional body of accountants. Founded in 1906, the Ulster Society has over 5,000 members throughout Northern Ireland. Additional survey insights: Two-thirds of members support the Executive pursuing the introduction of a lower rate of corporation tax for Northern Ireland Over half of members cite the need to address public sector inefficiency as a top priority to make the public finances more sustainable Two-thirds of members believe that while Northern Ireland offers a clear investment proposition to attract foreign direct investment to the region, more government supports are needed to bolster this offering 8 in 10 members believe childcare in Northern Ireland is currently unaffordable with 3 in 5 respondents reporting they have had to reduce their working hours as a result. Commenting, Chair of Chartered Accountants Ireland Ulster Society Paul Millar said:  “Despite the economic headwinds facing the economy as a result of inflation, skills shortages and the rising cost of doing business, Northern Ireland ultimately has the opportunity to reverse these trends by fully taking advantage of our unique trading position post-Brexit. “In this survey, a significant majority of our members rightly point to the dual EU/UK market access afforded to Northern Ireland as our biggest opportunity for growth over the next decade. If we can combine this with the introduction of a competitive corporation tax rate and an improved package of business supports to attract FDI, the effect on the economy could be transformative”. Commenting, Barry Doyle, President of Chartered Accountants Ireland said: “Financial confidence, while still muted, is recovering on 2022 levels. There is a notable rise in those that believe the economy is growing, and a sharp drop in those who feel that financial distress is increasing. The accountancy profession is fundamental to economic prosperity right across the island of Ireland, with almost 28,000 members supporting businesses on these shores alone. We have played a critical role in helping businesses in every sector to navigate uncertainty over the last few years, and we are ready to engage with business and political partners with renewed vigour to ensure Northern Ireland can avail of this economic opportunity.”   ENDS

The Institute recently hosted a webinar on the Small Companies Administrative Rescue Process (SCARP) - Practical Issues. This discussion with David Swinburne and Philip Maher of Mazars included how to prepare for a SCARP, what to look out for and key matters to be aware of when considering the process. There was also discussion around some practical issues including how SCARP is working in practice, dealing with creditors and excludable creditors.  The recording is available here. 

Last month we updated readers on developments in this space ahead of HMRC’s plan to widen the beta trial in 2024/25, commencing from 22 April. As set out in that update, HMRC has now expanded the beta trial and recently sent an email to agents providing information on how to sign qualifying clients up to the Making Tax Digital (“MTD”) for income tax trial. Further updates are set out below.   Suspension of meetings  The Institute is currently considering how best to support members in their preparations for this change and we will continue to attend HMRC forums on MTD. However, it should be noted that due to the pre-election period (known as purdah), HMRC has now suspended some forum meetings, including meetings on MTD.  Technical consultation on new regulations  HMRC has launched a technical consultation on proposed new regulations (“The Penalties for Failure to Pay Tax (Assessments) Regulations 2024”), which is running until 10 June 2024.   These draft regulations relate to the reformed penalty system for late payment of tax, which is set out in Schedule 26 to the Finance Act 2021. Penalty reform began for VAT taxpayers from 1 January 2023, and from April 2024 for Income Tax Self-Assessment (“SA”) for those participating in the MTD for income tax beta trial. For all other Income Tax SA taxpayers, penalty reform will commence from April 2026 as MTD for income tax begins to be mandated  Current legislation allows HMRC to assess a second late payment penalty within a two-year assessment time limit, at the point the outstanding tax is paid in full. However, HMRC is not able to assess this penalty if the tax remains unpaid. The proposed legislative change will allow the second payment penalty to be assessed towards the end of the time limit, in circumstances where the outstanding tax has not yet been paid in full. This will mean taxpayers will not be able to intentionally avoid a second late payment penalty by not paying their outstanding tax before the end of the two-year time limit.   New MTD manual   A new manual on how to use MTD for income tax has now been published. Since our last update, the number of available software packages, which already includes some of the big players, has been expanded from five to seven, with a range of other software packages in development. 

Today we are issuing a final reminder that the deadline for employers to provide employees with their P60 for 2023/24, either on paper or electronically, is Friday 31 May 2024. The P60 summarises the employee’s total pay and deductions for the year.   By that date, employers must give a P60 to all employees on payroll who were working for them on the last day of the tax year (5 April 2024). If an employer is exempt from filing payroll online, copies of P60s can be ordered from HMRC. 

After the Spring Budget took place on Wednesday 6 March, the Spring Finance Bill 2024 (official title Finance (No. 2) Bill 2023-24) was published. The Bill reflects many of the tax measures announced as part of the Spring Budget. It is currently awaiting Royal Assent with many stages having taken place at speed last week due to the announcement of the General Election which will take place on Thursday 4 July. Parliament is to be dissolved later this week on Thursday 30 May. 

In this week’s miscellaneous updates, HMRC has published guidance on using an agent to claim certain VAT refunds and guidance is also available for legal representatives on the information they need to tell HMRC to calculate the lump sum death benefit charge. The latest Agent Update is available which covers a range of areas and issues and HMRC is conducting research on the Income Record Viewer. And finally, HMRC’s latest Stakeholder Digest has been released which includes news of an update to HMRC’s Agent Standard, the standard which sets out HMRC’s expectations of tax agents and advisers in their dealings with HMRC and an overview of the way HMRC tackles the minority of agents who do not meet the standard.  Using an agent to claim VAT refunds  HMRC has added a section on using an agent to the following guidance pages:  VAT refunds for constructing a new charity building;  VAT refunds for new builds if you’re a DIY housebuilder; and  VAT refunds for conversions if you're a DIY housebuilder.  Guidance on lump sum death benefits and the abolition of the lifetime allowance  HMRC has published guidance for legal representatives on the information they need to provide to HMRC when calculating the lump sum death benefit charge. The legal representative is responsible for checking whether a chargeable amount arose, and for reporting any chargeable excess over the lump sum death benefit allowance to HMRC.   HMRC has also published a set of over 100 FAQs on the abolition of the lifetime allowance for pension schemes.  Latest Agent Update  Agent update: issue 120 is available now. Get the latest guidance and information including: moving all exports to the Customs Declaration Service;  the enhanced check your State Pension forecast service is now available;  how you could benefit from joining the UK Internal Market Scheme;  Investment Zone tax reliefs guidance; and  reporting profits on a tax year basis from 2024/25.  Research on the Income Record Viewer  HMRC is conducting research on the Income Record Viewer (“IRV”), which is their online tool for agents to view client information, such as tax code, pay and tax details and employment history. HMRC has launched a survey on the tool with a view to making future improvements. Responses to the survey are anonymous.  

In this week’s EU exit corner, we bring you the latest guidance updates and publications relevant to EU exit. The most recent Trader Support Service and Cabinet Officer Borders bulletins are also available. We issue another reminder that there is now just over a week to go until the 4 June 2024 deadline for making all export declarations via the Customs Declarations Service and not CHIEF. And finally, the National Audit Office has published its report on implementing an effective trade border in the UK.  NAO report   The NAO’s report, which was recently published, focuses on the movement of goods across the border. It covers:  the operation of the border since the end of the transition period in December 2020 (Part One), the introduction of a full border control regime and future risks (Part Two), and challenges and opportunities relating to the management of the border (Part Three); and  the implementation of arrangements relating to Northern Ireland (Part Four).   The report is based on information available up to April 2024 and has not evaluated the implementation of the new import controls introduced from 30 April 2024.  The report concludes as follows:  “Leaving the EU customs union and single market created large-scale change in arrangements for the movement of goods across the UK border. More than three years after the end of the transition period, full import controls are still not in place. In addition, the model’s operation is still to be tested and the government may not be able to apply controls consistently as the controls are phased in.  The government’s new border target operating model should reduce costs to traders in comparison to its initial plans. However, repeated delays in implementing controls have meant ongoing uncertainty and an increase in risk, and the government and border stakeholders have also incurred unnecessary costs. This could have been avoided if the government had established a clearer vision of how the border should operate from the start and had taken a more strategic and planned approach to implementation.  The government’s 2025 UK Border Strategy includes ambitious plans to use technology and data to facilitate the passage of legitimate trade, while still identifying people and goods at risk. Most stakeholders agree with this overall approach. However, there is no timetable for achieving these ambitions, and the extended phasing of the introduction of full import controls has meant slower progress on other elements of the Strategy.  It is a considerable challenge to manage several large programmes involving multiple departments and external stakeholders, and we have highlighted the delivery risks. To improve its chances of success, the government needs strong mechanisms for delivery and accountability, a more realistic approach to digital transformation, and the means to assess and report on border performance to enable improvement over time.  The UK government and the EU have agreed arrangements to simplify the movement of goods from GB to NI, and the UK government and NI authorities are working to implement these. However, some details remain to be confirmed, including the operational implications of the government’s recent Safeguarding the Union Command Paper. If NI is to benefit from its unique position, the UK government must provide the clarity required to give businesses the confidence to invest in and trade with NI and provide sufficient support to the Northern Ireland Civil Service to help it effectively enact its new responsibilities.”  Miscellaneous updated guidance etc.   Recently updated guidance, and publications relevant to EU exit are set out below:  Navigate the CDS Declaration Instructions for Imports;  List of customs training providers;  Goods Vehicle Movement Service codes for Data Element 5/23 of the Customs Declaration Service;  Apply to use simplified procedures for import or export (C&E48);  Report exports that arrived or left a UK port that were not notified in CDS;  Data Element 2/3 Documents and Other Reference Codes (National) of the Customs Declaration Service (CDS);  External temporary storage facilities codes for Data Element 5/23 of the Customs Declaration Service;  Notices made under the Taxation (Cross-border Trade) Act 2018;  Country codes for the Customs Declaration Service;  Currency codes for Data Element 4/10 of the Customs Declaration Service;  CDS Declaration Completion Instructions for Imports; and  Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service.