The research and development tax credit encourages new ways of thinking… just not, as it seems, from everyone, writes Dr Brendan McCarthy The most recent Worldwide R&D Incentives Reference Guide from EY demonstrates how most of the 46 jurisdictions discussed in the guide give preferential tax treatment to business research and development (R&D) expenditure in broadly similar ways. Subject to maintaining detailed records, eligible companies can typically offset the credit against their other tax liabilities or claim a refund in the form of cold, hard cash. When we consider the amount of money large pharmaceutical, medical device and other similar companies are likely to invest in R&D on an ongoing basis, it should come as no surprise that this credit can often run into many hundreds of thousands of euros, facilitating even further investment in R&D by both multinational companies and SMEs year after year. Ireland remains an outlier, however, in two important respects. First, for accounting periods commencing on or after 1 January 2024, eligible companies in Ireland can now claim a credit of 30 percent (previously 25%) of qualifying R&D expenditure, payable in three annual instalments. This amount exceeds that offered by most Western countries (in some cases by double digits) and is twice that offered by New Zealand, a similarly sized economy. However, apart from the level of the credit itself, what sets the Irish regime even further apart from most other jurisdictions is the concept of ‘key employees’. Recognising the reality that it is not companies that have innovative ideas but rather the people working for them, eligible companies have a further option: they can choose to use the credit to reduce the income tax liabilities of their R&D workers. Not all workers are eligible. Irish legislation stipulates that they must spend at least half of their time working in R&D, cannot be company directors, and cannot hold more than a five percent stake in their company. In other words, they must be bona fide R&D workers and cannot have a vested interest in the idea's success. Opting to surrender the credit in this way presents a dual benefit – not only does the company stand to benefit from the R&D underway, but the wider workforce is also incentivised to continue their good work. Even the most well-meaning of provisions can have unfortunate consequences, however. Having satisfied the criteria of being a key employee, the legislation states that the individual’s effective tax rate, after claiming the credit, can be no lower than 23 percent. This stipulation inevitably favours those paying tax at the higher rates (predominantly, the more senior and thus higher-paid workers), effectively leaving those paying the lower rates (the lower-paid, junior staff) out in the cold. Research has shown that employee input, or ‘voice’, can make a positive contribution to an organisation through, amongst other things, increased innovation, the identification of new and more efficient work practices, and the early detection and prevention of problems. This is irrespective of the employee’s rank or tenure within the organisation. Yet, this same research has also shown that employees, particularly those at the most junior levels, frequently withhold their voice on a wide variety of matters. One of the primary reasons for this is an overwhelming sense of futility, fuelled by an awareness of their low rank or position and a sense of ‘it’s not my place’. The requirement that the R&D worker’s effective tax rate can be no lower than 23 percent arguably adds fuel to this fire. By favouring those on higher incomes, the message seems to be that innovative ideas from lower earners are not worth the company’s time or investment. This baffling provision is not only overtly managerially biased but is patently contra to the spirit of the legislation, the primary objective of which was the promotion of new ideas and new ways of thinking. Moreover, it is hopelessly out of date. The provisions governing the R&D tax credit were first introduced into Irish tax two decades ago. Together with one of the lowest corporation tax rates on trading profits in the world, it remains central to the country’s efforts in attracting foreign direct investment. By leading the way in championing the contribution of ‘key employees’ and recently increasing the amount of the credit from 25 to 30 percent, successive Irish governments have not only shown a continued commitment to the R&D tax credit regime but also a willingness to make adjustments to its provisions, in a more equitable pursuit of its overall objective. So, it is fair to say that the Irish R&D tax credit encourages new ways of thinking… just not, as it seems, from everyone. It’s time we gave this some thought. Dr Brendan McCarthy is Assistant Professor in Tax at the University of Limerick

Tax must be considered as part of the Corporate Sustainability Reporting Directive’s double materiality assessment, explains Aidan Lucey The aim of the EU’s Corporate Sustainability Reporting Directive (CSRD) is to drive accountability and transparency by mandating companies operating in the EU to disclose information on material sustainability topics publicly. Even if companies have reported non-financial data in the past, they will likely need to expand the nature and extent of their disclosures. For some companies, tax could be considered a material sustainability topic, given the significance of tax contributions to society and heightened investor scrutiny. This means they will need to disclose information on tax publicly, too. Therefore, companies must understand the specific tax disclosures that may be required under CSRD. CSRD and double materiality Companies within the scope of CSRD are required to make disclosures on material sustainability topics in accordance with the European Sustainability Reporting Standards (ESRS). The ESRS covers sustainability topics across environmental, social and governance pillars and prescribe specific disclosure requirements. To determine the sustainability topics to be disclosed, companies must carry out a double materiality assessment. This involves assessing a company’s impact on the environment and society (“impact materiality”) and an assessment of how sustainability topics may affect the future performance of the company (“financial materiality”). If a sustainability topic is material to a company, but is not addressed by the ESRS, the company must still disclose information about it to enable readers to understand its sustainability-related impacts, risks and opportunities. Tax as a material topic Interestingly, the European Financial Reporting Advisory Group (EFRAG), which developed the CSRD standards, explicitly calls out tax as one of the topics on which organisations could make disclosures. In determining what sustainability topics are material for a business and its stakeholders, companies must consider many factors. While materiality considerations will differ for every organisation based on their specific sustainability and stakeholder profile, a range of factors could make tax a material consideration. These are outlined below. Social impact Tax is not just a cost of doing business, it is also a social responsibility. The taxes paid by an organisation, including those that it collects on behalf of governments, can represent its biggest monetary contribution to society. Those taxes fund public services, green infrastructure and community projects. Consequently, tax can be seen as a powerful indicator of a company’s societal impact. To assess this impact, stakeholders are demanding a greater level of tax transparency. They want to understand a company’s approach to tax, how tax matters are governed, and how much taxes are paid. Investors Tax is being factored into investor considerations when assessing the sustainability of a business. An organisation’s approach to tax can pose significant risks that affect investment returns in the medium and long term. To address these concerns, investors are taking steps to influence companies to make more comprehensive tax disclosures that will allow them to evaluate not only financial aspects but also governance and reputational risks associated with their approach to tax. Some investors have released codes of conduct encouraging transparency on tax from investee companies. Others have filed shareholder motions mandating tax disclosures under GRI 207, a specific tax standard released by the Global Reporting Initiative (GRI) to enable companies to disclose tax as part of their sustainability reporting. Tax disclosures under the CSRD can provide companies with an opportunity to build trust with investors, customers and society. Even where a company concludes that tax is not a material topic in its own right—possibly because other sustainability topics are viewed as higher priorities—tax disclosures could be considered under an existing ESRS. Tax disclosures required Where an organisation deems tax a material topic, EFRAG has indicated that GRI 207 could be used as the basis for its tax disclosures. GRI 207 consists of four categories of disclosures: Disclosure 207-1: Approach to tax. This requires an organisation to disclose details on its tax strategy, who oversees it, and how it aligns with its broader sustainability strategy. Disclosure 207-2: Tax governance, control, and risk management. This requires the disclosure of information about an organisation’s tax governance structure and how tax risks are identified, managed and monitored. Disclosure 207-3: Stakeholder engagement and management of concerns related to tax. This disclosure considers how an organisation engages with its stakeholders on tax matters. Disclosure 207-4: Country-by-country reporting. This disclosure requires an organisation to report on quantitative data, including its revenue, tax, and business activities on a country-by-country basis. A double materiality assessment is an essential step towards CSRD compliance. Full engagement between tax departments and sustainability teams will ensure that tax impacts, risks and opportunities are identified and considered in the double materiality assessment. Aidan Lucey is Tax Leader for CSRD at PwC Ireland

What will tomorrow bring for the role of the Chartered Accountant and what changes are already taking hold today? Accountancy Ireland talks to four members of ACA Professionals about their experiences and expectations The role of the accountant is evolving and with it the expectations and perceptions of younger generations building careers in the profession. Here, four members of the Institute’s ACA Professionals Committee tell us about their hopes and aspirations for the future and career experiences today. Brendan Brophy I grew up in Perth, Australia, and studied business and accounting at Edith Cowan University, later obtaining a master’s in finance from University College Dublin. I qualified as a Chartered Accountant in 2016 and have since worked in both accounting and taxation. I am currently Senior Cost Accountant with Square and Chair of the ACA Professionals Committee of Chartered Accountants Ireland. I started my university journey in 2010 with a general interest in business, carrying a nascent curiosity about companies and their financial workings. My exact career direction was unknown until I encountered my first accounting lecture, however. That introduction to the foundational principles of accounting really resonated. It was during my first year at university that I had the privilege of attending a presentation by Chartered Accountants Australia. The session explored the prestigious career path offered by the ACA qualification, highlighting its value as an international career passport. Continuous learning The journey to becoming a Chartered Accountant, while enjoyable, has also posed distinct challenges. It requires extensive commitment to ongoing study and capacity to get to grips with deep knowledge across all facets of the discipline. What has surprised me most hasn’t been the rigour of the qualification process, but the ongoing need for continuous learning and adaptation post-qualification. The field of accounting is continuously evolving across standards, business practices, regulatory frameworks and technology. Expertise considered cutting-edge five years ago may no longer suffice today, so staying ahead of the curve is not merely an option, but a necessity for Chartered Accountants. Right now, technology is one of the most significant drivers of change in our field, redefining the boundaries of what’s possible. Advances in technology are outpacing existing regulatory frameworks, presenting both challenges and opportunities,and requiring us to anticipate and adapt to changes rather than respond to them retrospectively. Prime examples include artificial intelligence and cryptocurrency. The imperative for accountants today is to have a proactive mindset, enabling us to foresee emerging trends and incorporate them into our practices. Agents of change Becoming a Chartered Accountant is not just about mastering the intricacies of finance and accounting; it is about earning a pivotal seat at the decision-making table within any organisation. This privileged position allows Chartered Accountants to influence key business decisions directly, facilitating change that extends beyond the confines of a single company to impact the broader industry and regulatory environment. The role we play in guiding financial strategy, ethical standards and sustainable practices enables us to be agents of change, influencing economic outcomes and contributing to the shaping of regulatory frameworks that govern our profession and the business world at large. Anne Carter I studied business and accountancy at Galway-Mayo Institute of Technology and went on to qualify as a Chartered Accountant with DHKN in Galway in 2017. In between, I worked in retail banking, travelled to Australia and New Zealand on a Working Holiday Visa and moved to London for two years, where I earned a diploma in sound engineering. My journey to becoming a Chartered Accountant was triggered by my curiosity to understand the nuts and bolts of how businesses operate, and by my interest in maths and accounting from a young age. The opportunities for professional development associated with the ACA qualification really attracted me; the scope for continued learning and career advancement. The qualification opens doors. I saw it as a pathway to hone my skills, gain valuable experience and continue to develop. During my training contract with DHKN, I worked across audit, accounts preparation, income tax and corporation tax and, after qualifying, I moved to Dublin to join the internal audit function at GameStop. I have been with CRH plc now since 2018 and currently work on our Strategic Projects Team. Potential of technology I think technology has a lot of potential to allow our profession to develop broader skillsets and move more into advisory work, strategic decision-making and the actual interpretation of financial data. Artificial intelligence, automation and data analytics are all transforming the way accountants work and the services we provide. This will only increase over the next decade as more of the time-consuming or manual tasks we do today become automated. My career advice to younger members and students is to be open to change and to exploring different areas or opportunity within the field of accounting – adopt a growth mindset, set career goals, take ownership of your professional development and seek out advice and feedback from managers and peers. Claire Doyle I grew up in a small village called Leitrim in Co. Down and studied accounting at Queen’s University Belfast. I am also currently studying for a post-graduate diploma in sustainable financial technology and innovation at Maynooth University. I qualified as a Chartered Accountant in 2019 with KPMG in Belfast and I am currently International Tax Manager with PTC Therapeutics at its international headquarters in Dublin. At 17, I really struggled to understand what I should do for my career. My mother was a teacher, my father had set up his own business and my older brothers either worked, or were pursuing careers, in construction. Having watched them having to emigrate during the recession, I knew I wanted to pursue a qualification that would deliver high-quality jobs, global reach and allow me to carve my own path. Turning point During my second year at university, tragedy struck our family when we lost my brother Ryan in Australia. This really became the turning point in my life and the direction of my career. In the following months, I decided to apply for a year-long work placement with KPMG in Dublin so I would have the experience to know that becoming a Chartered Accountant was definitely the right path for me. It was a real eye-opener and ultimately brought me one step closer to starting my training contract with KPMG in Belfast. After my training contract ended, I decided to move into industry and take up a position that would allow me to gain more practical in-depth experience in the life science sector. Childcare reform Right now, I think childcare reform is needed across the island of Ireland to support working parents and reduce the financial burden and stress associated with finding a place for children and keeping parents in the workforce. Key to the retention of working parents in our profession and others is ensuring that there are adequate provisions in place to allow for reduced working hours. If a working parent decides to reduce their hours, I don’t believe this should mean that they have to condense five days of work into four. Transformative role I believe that accounting as a profession has the power to promote financial transparency, accountability and sustainability. Chartered Accountants are seen as trusted advisors. We can help our companies to understand their impact and reporting obligations across the three pillars of environmental, social and governance (ESG) and educate them on important matters, such as the UN’s Sustainable Development Goals (SDGs). Our ability to influence policy and advocate on behalf of the public is vitally important to supporting the Government in determining realistic targets in support of Ireland’s Climate Action Plan. The Institute’s collaboration with Chartered Accountants Worldwide allows us to amplify our impact and drive progress towards the achievement of the SDGs. Sinéad Nolan I studied both business and accounting and finance at undergraduate level and then did a master’s in accounting at Maynooth University. I qualified as a Chartered Accountant in 2017 with RSM Farrell Grant Sparks, which merged with Grant Thornton during my training contract. I then worked with the National Transport Authority as a Rural Transport Finance and Governance Accountant for one year before joining AXA Insurance in the role of Financial Accountant and, for a time, worked on the planning and analysis team and on secondment to the strategy team. I knew from an early age that I wanted to become a Chartered Accountant. I gained invaluable experience during Transition Year through work experience with O’Brien & Co. in Rathmines. I will be forever grateful for the accounting experience Tom O’Brien gave me back then at just 16 years of age. From day one at college, it was communicated to us how highly regarded the Chartered Accountant qualification is. The international recognition and respect the ACA qualification is held in really appealed to me. The work opportunities that come with it are endless. Welcome change ESG and, in particular, sustainability are becoming more important, especially among younger generations starting their career. Chartered Accountants and companies today are actively working to achieve their sustainability goals. I believe Chartered Accountants can bring about powerful change, especially with regards to sustainability, by encouraging social responsibility and the adoption of sustainable practices among entities of all sizes. I also see positive change with regards to gender equality in our profession and beyond, which is very welcome, and I believe we will see more women in senior positions in the future. I am lucky enough to see this in action at AXA Ireland, where there is a culture that fosters inclusion and a better working world for women.

Consultative Committee of Accountancy Bodies – Ireland (CCAB-I) Introduction to members of the Insolvency Committee Welcome to another edition of the series which will introduce members of the Consultative Committee of Accountancy Bodies – Ireland (CCAB-I) Insolvency Committee over the coming months. We hope to provide information on the work of the Insolvency Committee and insights into the careers and experience of our Committee members. Today we will hear from Shane McAleer. Shane is a Director in Insolvency at Somers Murphy & Earl with over 15 years of experience of advising on a variety of formal and informal restructurings. Shane jointed the CCAB-I Insolvency Committee in 2018. Tell us about your career to date and your route to being an Insolvency Practitioner I grew up in Belfast and from a young age worked with my Dad in the family business. I learned a lot of my good and bad business habits from Dad. As my wife would say “Shane has never paid full price for anything.” Accountancy, never mind Insolvency, was far from radar growing up. Sitting in a lecture theatre in St. Malachy’s College at 17 years old deciding what University courses I should apply for on my UCAS Form was a daunting thought. For some reason Accountancy was my decision. And, I have to say I have never looked back. During a summer term in University, I did some work experience in BDO Belfast where I was given my first taste of insolvency having worked on a few liquidations. Roll forward to 2000, I joined BDO Simpson Xavier where that piece of work experience landed me in the Restructuring department where my insolvency journey began. After qualifying as a Chartered Accountant in BDO, and a short stint in BDO Sydney, I moved to Moore Stephens Caplin Meehan and then Farrell Grant Sparks, finally ending up in Somers Murphy & Earl with Derek Earl. I took over the Insolvency practice in 2019 and business has been continually growing and developing.        Are you where you expected to be in your career? I can say that I am very happy with where I am in my career today. If anything, I have learned in my 24-year career to date is, to always expect the unexpected! What was the best career advice you got along the way? In two words “Stop” and “Listen.” Throughout my career I have been lucky to have worked in several practices and in each one got the benefit of working and learning alongside some of the most experienced insolvency practitioners in the country. Based on your own experience, what advice do you have for young professionals looking to build a career in corporate insolvency? In my experience working in Corporate Insolvency, no two days are the same. If you want to challenge yourself and develop new and broader skills, then Insolvency is a path worth considering. There are many paths to working in Corporate Insolvency you should consider a professional qualification which will give you a strong knowledge and basic skills base but more importantly the ability to grow and develop professionally. In today’s market many firms are looking for enthusiastic and energetic young professionals keen on building a career in corporate insolvency. How would you define your work style, and how has this evolved over the years? I am not sure I know what my style is! I am at heart a people person. Unfortunately, in our world of insolvency I come across a lot of difficult and emotional stories which has had an impact on my approach to dealing with people. Notwithstanding the emotional side of insolvency, it is important to have a structure and plan in place of what you need to do along with a realistic period of achieving your plan. In terms of managing teams and individuals, what are your insights and views? In Insolvency, everyone must ‘roll up their sleeves.’ In any assignment, it is important that there is clear delegation to the team and each person knows what their role is and reasons for what they are doing. Promoting and encouraging personal and professional development is essential. This should be worked one with each person on an individual basis to ensure that the best path forward is agreed upon. A person’s growth will not only benefit them personally but will provide additional skills to the team. What about communication and negotiating the typical ups and downs of working life? Effective communication is always important. Do not assume that someone knows or should know something. Whether you are communicating with someone or waiting on a response from someone be clear at all times of what your point is or what you require. Has networking played an important part in your career? Your reputation is key to any future success and building a career. Effective networking with the right contacts and people allows you access to the ability to get work and refer work and developing your reputation. Networking has been an essential part of my 24-year career, I am still in contact with many friends and colleagues who I trained and worked with along my career because you just never know where the next referral will come from. What is the current position with regards to the level of insolvencies in Ireland? If only I had a crystal ball! Covid, an energy crisis, interest rate increases, increased minimum wage, increased costs and €1.7bn of warehouse debt to be repaid. The current level of insolvencies based on the current climate appear low. From chatting with other insolvency practitioners there is an expectation that there will be more insolvencies, the question is when?   Disclaimer: The views of contributors to this series of articles may differ from official Institute and Consultative Committee of Accountancy Bodies - Ireland (CCAB-I) policies and are not necessarily endorsed by the Institute of Chartered Accountants in Ireland, its Council, its committees or any other person or entity associated with the Institute. The publishers, editor, and authors accept no responsibility for any errors or omissions or any loss resulting from any person acting, or refraining from acting, because of views expressed or advertisements appearing in this publication.

Over the course of the last few weeks, we have examined two of the proposals in HMRC’s long planned consultation “Raising standards in the tax advice market” which contains three potential options to regulate the UK tax agent market. This week we are seeking your feedback on option three, regulation by a separate statutory government body, in addition to approaches to strengthen the controls on access to HMRC’s services for tax practitioners. HMRC is also seeking to draft a legislative definition of a tax practitioner to support implementation and sets out the categories of who should be regulated in Chapter 8. Please share your views on this consultation by Tuesday 7 May 2024.   Regulation by a separate statutory government body   More information on this option is set out in Chapter 6. This option would see the introduction of a new independent regulator or expansion of the remit of an existing regulator to regulate tax practitioners. According to the consultation, “a single independent regulator would provide consistency across the market. Having an arm’s length body would avoid potential conflicts of interest arising from HMRC acting as a regulator and avoid a potential race to the bottom.”  The government regulator would set standards, carry out checks on tax practitioners seeking to be regulated, and ensure they meet the required criteria. This could include conducting an annual renewals process to ensure all information is up to date and correct. As is common with professional regulators, this body could have a role in supervising tax practitioners including inspections of tax practitioners on a risk-assessed basis to check they continue to meet expected standards, investigating issues and complaints, and enforcing sanctions.  This regulatory body could introduce “customer support routes” including establishing a complaints process, ensuring transparency, and supporting redress claims. The regulator could be responsible for providing support and guidance to the profession and ensuring tax practitioners receive updates on the latest changes in the tax system.  Within this model there are options about how the regulator could be set up and the role that current professional bodies could play. Current professional body members could be automatically registered with the regulator as they have already undergone a series of checks and professional bodies could retain their role as providers of qualifications and ongoing practice support for their members.  The consultation considers that establishing a new regulator in this way “would provide the opportunity to create a tailored regulatory solution for the market which is adaptable for future needs.”  However, potential problems with this model include that adding a new regulator to an already complicated regulatory landscape for tax and accountancy may cause confusion, and this is likely to be the most expensive of the potential approaches, as it would involve costs for the government and for all tax practitioners. The government sees this approach as a fallback option if the professional body lead approach is not practical or effective. Questions 8-10 specifically seek feedback on this approach.  Access to HMRC’s services for tax practitioners   This aspect of the consultation examines the first step of mandating registration with HMRC for tax practitioners who wish to interact with HMRC on behalf of their clients, and the requirements that HMRC should establish to enable registration.  Alongside the broader proposals on raising standards, the government wants to improve the way that tax practitioners register with HMRC and intends to mandate registration for all tax practitioners who wish to interact with HMRC.   Together with mandated registration, HMRC would automate and streamline the existing registration routes for tax practitioners, with the aim of providing a better service. At the point of registration, HMRC would check that the tax practitioner is compliant with requirements to register for anti-money laundering supervision and is up to date with their tax affairs. HMRC would then periodically reconfirm ongoing compliance with these requirements.   This would aim to provide assurance that registered tax practitioners continue to meet basic standards while interacting with HMRC on behalf of a client.  The government therefore intends to improve registration now, assuring that basic standards are in place for all agent services and is asking for views on the proposal to mandate registration, alongside providing an automated, streamlined way for tax practitioners to register with HMRC.   The consultation recognises that whilst this step by itself is unlikely to fundamentally raise standards in the tax advice market, it would be an essential enabler for a strengthened regulatory framework. It could also be implemented if the broader proposals for a strengthened regulatory framework are not taken forward.  Legislative definition of tax practitioner   As part of this project, the Government also intends to draft a legislative definition of a tax practitioner “as a provider of tax advice and services.” This aspect will be subject to further consultation however the definition will include the following provisions:-  it will cover the full range of business entities operating in the market, that is, individuals, firms, and sole practitioners;  the advice or assistance caught will be  given by way of business, so that friends and family are not inadvertently captured;   provided in relation to UK taxation; and  provided directly, indirectly, or at the request of someone other than the client.  The definition will also set out what is meant by advice or assistance. This will include acting on behalf of a client in their dealings with HMRC or another UK tax authority in relation to tax. Depending on the scope of the regulatory framework, it may also include advising a client in relation to tax. Questions 25 and 26 of the current consultation specifically deal with this aspect.   

In recent weeks we have issued several reminders that 30 April 2024 is the deadline for the end of the VAT margin scheme for second hand vehicles moved to Northern Ireland from Great Britain prior to 1 May 2023. If these vehicles are sold after 30 April 2024, VAT will therefore be chargeable on the full selling price and not on the margin made. At the request of HMRC, Chartered Accountants Ireland gathered evidence recently from local car dealers which demonstrates that many dealers are still experiencing delays in selling these vehicles for a range of reasons, including the economic environment and delays in MOT testing. Click read more for an update on our recent meeting with HMRC on this issue. The Institute met at the end of last month at the request of HMRC with their VAT policy team to discuss and present the evidence gathered from local dealers. The Institute also explored the potential for either removal of the deadline, a type of amnesty, or another extension.  Readers are advised that HMRC is insistent that the deadline remains 30 April 2024 and that there will not be a further extension. According to HMRC, a deadline is required for “legal certainty”. Despite presenting evidence of the ongoing difficulties being experienced in selling these vehicles, it is disappointing that the cliff edge deadline of 30 April 2024 remains in place.    

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. Readers are advised that this bulletin contains important information on the next phase in the implementation of the UK’s new import controls, known as the Border Target Operating Model, which commences from 30 April 2024 when  documentary and risk-based identity and physical checks on medium-risk animal products, plants, plant products and high-risk food (and feed) of non-animal origin imported from the from the EU will begin.   Miscellaneous updated guidance etc.   Recently updated guidance, and publications relevant to EU exit are set out below:-  Customs Declaration Service: service availability and issues;  Reference Document for The Customs (Northern Ireland) (EU Exit) Regulations 2020;  Appendix 1: DE 1/10: Requested and Previous Procedure Codes;  Appendix 1: DE 1/10: Requested and Previous Procedure Codes of the Customs Declaration Service (CDS);  CDS Declaration Completion Instructions for Imports;  Customs declaration completion requirements for Great Britain;  Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service;  Appendix 2: DE 1/11: Additional Procedure Codes of the Customs Declaration Service (CDS);  Authorisation type codes for Data Element 3/39 of the Customs Declaration Service;  Data Element 2/3 Documents and Other Reference Codes (National) of the CustomsDeclaration Service (CDS);  Additional Information (AI) Statement Codes for Data Element 2/2 of the Customs Declaration Service (CDS);  Reference Documents for The Customs Tariff (Suspension of Import Duty Rates) (EU Exit) Regulations 2020; and  Customs, VAT and excise UK transition legislation from 1 January 2021. 

HMRC’s latest schedule of live and recorded webinars for tax agents is available for booking. Spaces are limited, so take a look now and save your place. 

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. 

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 from 12-16 April 2024. Check the relevant page for information on planned downtime.   In particular, we have been advised that as part of regular maintenance, the following services will be unavailable between the stated times below. The HMRC Service Availability pages will be updated to reflect the affected services.  Services unavailable from 5.30pm Friday 12 April 2024 to 9am 16 April 2024:-  Trusts and Estates;  The Annual Tax on Enveloped Dwellings;  CGT Property Disposal;   EPAYE;  VAT Registration Service;    Claim VAT Enrolment;   VAT View and Change;   Plastic Packaging Tax; and  The Agent Services Account. 

Navigating the complexities of sustainability leadership demands a multifaceted approach, writes Catherine Duggan More companies are grappling with a rising regulatory burden and heightened stakeholder expectations regarding sustainability, presenting the need for a captain to lead the team. Here is a selection of the components that can help make this role successful. 1. Knowledge of the business The impacts, risks and opportunities sustainability presents for each business are unique. Understanding sustainability, along with intimate knowledge of your business operations, stakeholders and future strategic plans, is critical to ensuring the successful integration of the sustainability agenda. 2. Commercial mindset Perhaps more than other disciplines, sustainability tends to attract people who are passionate about the topic and driven by the need to be change-makers. While enthusiasm is certainly necessary, particularly on more challenging days, the ability to consider and incorporate commercial aspects into the wider conversation can prove more effective than passion alone. 3. Risk management While sustainability may be a developing area of expertise in companies, risk management is not. The risk posed by the transition – or failure to transition – to a more sustainable economy can and should be considered through existing risk management processes, enhanced skill sets and frameworks. Being familiar with the vocabulary and the approach that is being taken can help with the incorporation of sustainability considerations. 4. Communication management Many of the sustainability regulations that are being introduced focus on disclosing sustainability-related information to facilitate stakeholder decision-making. The implications of these disclosures must be understood in the wider context of any supervisory oversight. In addition, consistency of investor messaging and alignment with previous external disclosures, public commitments and marketing campaigns are crucial factors for the effective management of external communications. 5. Stakeholder management Getting internal stakeholders onside is the most fundamental skill required to develop and deliver a credible sustainability programme. The ultimate goal of a sustainability function is that it should become business as usual, part of everyone’s day job. Until that point, support is required from all parts of the business at a time when resources are often already at capacity. The ability to tailor messaging to specific functions, outlining the drivers, risks, opportunities and executive support, is critical. 6. Change management All parts of the business will eventually feel the impact of sustainability through the implementation of a new strategy, regulation, processes or responsibilities. Agnostic of sustainability, change management is required to embed this level of transformation and support into the culture of an organisation. 7. Resilience While sustainability aims to deliver long-term resilience for people, the planet and profit, a degree of personal resilience is required to chart the path. In a fluid regulatory environment, an organised and curious mind is needed to develop best practices. A support network is also important to ensure the workload is shared. Building a sustainable future together While the above list may seem unrealistic, it’s important to emphasise sustainability’s ‘team’ nature and the need for support from across the organisation. Identifying a resource proficient in all of the skills outlined above is a challenge. Securing someone with working knowledge of some or all of these areas – and who can upskill – is more achievable. Few people today began their career with the intention of becoming a sustainability professional, but there is now a growing community forging a new path for their companies, with the aim of highlighting the reality that we are all in the same boat and the water is rising. Catherine Duggan is Director of Sustainability at Grant Thornton

Ireland’s CFOs continue to prioritise cost control and efficiency over investment in AI but will they pay the price further down the road? asks Derarca Dennis As Ireland’s Chief Financial Officers (CFOs) step up to future-proof the finance function, their role in leveraging technology to improve efficiencies is becoming increasingly pivotal. According to the EY Ireland CFO Survey 2024, finance leaders are not just looking to elevate business performance, they are also actively seeking to tap into the potential of technology while simultaneously strengthening their collaborative alignment with Chief Technology Officers (CTOs). The continued focus on technology investment is unsurprising, considering that 47 percent of respondents identified manual processes and controls as an area where time is used least efficiently in the finance function. It is perplexing that such a high number of respondents continue to cite manual processes and controls as an area for improvement in the finance function. This suggests that organisations have some way to go in their automation efforts, and significant further investment in technology will be required over the coming years. AI and the finance function Despite the investment in technology, the survey results for artificial intelligence (AI) indicate that it is a low priority for organisations right now. Finance leaders in Ireland are still at the very early stages of Generative AI (GenAI) adoption and are firmly focused on using cost reduction and efficiency gains to realise growth. AI use remains modest, with just 26 percent claiming to have leveraged it for enhanced efficiency, automating manual tasks and risk detection, among other use cases. The uptake of GenAI is even lower at just 15 percent. This may come as a surprise to some. While GenAI has been commanding the headlines over the past 15 months, the technology is still not at the stage where it can be employed to carry out advanced functions in finance departments. CFOs are naturally exercising caution until they see some applications proving that GenAI can be trusted in terms of output and security. Just six percent of respondents say they will leverage advanced AI to enhance the finance function or acquire AI skills in the next two years. The figure for a longer five-year span is only moderately higher, with nine percent saying they will integrate AI and advanced AI into the finance function in that timeframe. The results of the survey indicate that organisations are still at the discovery and use case definition stage in relation to AI. Automation It is surprising that greater use has not been made of the technology for automation purposes, given the continued inefficiencies created by manual processes and controls in finance functions. Interestingly, the survey shows a fairly significant budget increase is anticipated, albeit from a low base, for advanced AI (including GenAI) from one to 3.2 percent in the next two years. This suggests an openness to applying the technology as soon as use cases are identified and better understood. Not all AI solutions are expensive or require custom development. To get their organisations to accelerate the AI journey, CFOs can recommend adopting pre-built AI solutions that drive cost efficiency. Cybersecurity In their role as strategic business partners, CFOs must do more than just comprehend the organisation’s risk tolerance; they are also responsible for steering the budget towards areas that need more attention. Just 39 percent of the respondents in the EY Ireland survey say they have ramped up investment in security tools, compared with 60 percent in 2023. This may indicate a degree of complacency regarding cybersecurity, or it could be that investments have begun to plateau following significant increases in recent years. In a very welcome finding, 31 percent of the respondents say they instituted a cybersecurity task force compared with the eight percent in 2023. CFOs’ north star The relatively low priority given to technology-driven transformation and the low rate of AI adoption in finance functions is surprising given current talent shortages. Right now, cost control and efficiency remain the north star for finance leaders in Ireland. Derarca Denis is Assurance Partner and Sustainability Services Lead at EY Ireland 

Amid rising cyber threats, integrating cybersecurity into the due diligence process for business acquisitions is becoming increasingly important, writes Mark Butler With the recent rise in digital data breaches, cybersecurity’s critical role in due diligence engagements during business acquisitions cannot be underestimated. Embedding a cybersecurity-focused lens into the due diligence framework is an essential part of helping accountants and their clients tackle and manage potential vulnerabilities before investing proactively. This approach can strengthen defence against cyber threats, support informed, strategic decision-making and enhance a company’s resilience in the face of digital-age risks while ensuring full visibility of the purchaser’s potential exposure. The urgency of prioritising cybersecurity due diligence hinges on four key considerations: Assessing the business’s technological framework In today’s digital-driven business environment, a company’s technological infrastructure is integral to its operational success. Cybersecurity due diligence offers a deep dive into the resilience of the business’s networks, systems and software, revealing potential vulnerabilities. This critical assessment aids in understanding the implications and costs associated with securing or upgrading technological assets post-acquisition, facilitating strategic planning and integration efforts. Ensuring the security of sensitive information The acquisition process provides access to sensitive data, from client details and intellectual property to financial records and employee information. A focused cybersecurity due diligence process is crucial for evaluating how robust the target company’s data protection measures are. Early identification of security gaps enables the implementation of stringent safeguards, thus securing the integrity and confidentiality of vital data assets against potential breaches. Mitigating financial and legal exposures Cybersecurity breaches carry operational risks and significant financial and legal ramifications. A thorough cybersecurity due diligence process can uncover potential liabilities arising from data breaches, regulatory non-compliance and other legal challenges. Forearmed with this knowledge, acquirers can better negotiate the terms of the acquisition, allocate resources for addressing identified risks, and adjust the purchase price to reflect any investments needed to improve cybersecurity. Safeguarding business continuity and brand reputation Maintaining business continuity and reputation is paramount for a successful acquisition. Cyber incidents can severely disrupt business activities, erode customer trust and damage brands. By incorporating cybersecurity due diligence, potential threats can be identified and mitigated through comprehensive incident response planning. This proactive strategy ensures that appropriate measures are in place to minimise the impact of cyber threats on the company’s operational integrity and reputation. Prioritising cybersecurity within the due diligence framework is not merely a precautionary measure; it is a strategic business imperative that gives the purchaser adequate visibility of the acquired business. It can support a thorough assessment of technology-related risks, fortify the protection of sensitive data, mitigate potential financial and legal consequences, and protect the viability and reputation of the business. Finding expertise in cybersecurity can be difficult, however. I advise seeking out recognised specialists offering comprehensive assessments that adhere to international standards. This approach during the due diligence process can help accountants and their clients to understand and proactively address the cybersecurity challenges that come with business acquisitions, laying the groundwork for long-term success. Mark Butler is Managing Partner at HLB Ireland

Welcome to the latest edition of Technical Roundup. In developments since the last edition, IAASA has issued a revised version of ISA (Ireland) 505 – External Confirmations. The revised standard is effective for audits of financial statements for periods beginning on or after 15 December 2024 with early adoption permitted.  The Financial Reporting Council has welcomed the culmination of the first phase of the government’s review of non-financial reporting requirements for UK companies which aims to simplify the reporting framework as part of its Smarter Regulation agenda. Read more on these and other developments that may be of interest to members below. Financial Reporting The Financial Reporting Council has issued its final amendments to the FRS 102 and FRS 105 accounting standards, which will finalise the periodic review of the standards. The amendments (of which most come into effect from 1 January 2026) include changes to revenue recognition rules under FRS 102 and 105, and changes in the way some leases are measured & recognised under FRS 102. For more information please see our recent news item. The FRC has issued some guidance material relating to the amendments. They are also planning a webinar to discuss the amendments to the standards on 15 May. The International Accounting Standards Board’s (IASB) deadline for responding to their recent Exposure Draft  Financial Instruments with Characteristics of Equity Proposed amendments to IAS 32, IFRS 7 and IAS 1 has passed. The Financial Reporting Technical Committee of Chartered Accountants Ireland has issued its response to this consultation, which includes some recommendations to the IASB in finalising the project. The UK Endorsement Board has also published its response to the same consultation. The IASB has announced that it plans to issue its next IFRS standard, IFRS 18 Presentation and Disclosure in Financial Statements, on 9 April 2024. The IASB, in conjunction with the Education Committee and the Financial Reporting Standards Committee of the European Accounting Association (EAA) is holding an education workshop on 22 April to provide an overview of the standard. The IASB has published for public comment the Addendum to the Exposure Draft Third edition of the IFRS for SMEs Accounting Standard, which supplements the exposure draft published in September 2022. The deadline for responding to this consultation is 31 July 2024. The IFRS Interpretations Committee (IFRIC) has issued its Q1 2024 podcast. This considers some recent activity, including the treatment of climate related commitments under IAS 37 Provisions Contingent Liabilities and Contingent Assets. IFRIC has also released its March 2024 update. The IFRS Foundation has issued its March 2024 monthly news summary as well as its National Standard Setters Newsletter. The IASB has also issued a March 2024 update and podcast. EFRAG, the European Financial Reporting Advisory Group has extended the deadline for responding to its two surveys on the post-implementation review of IFRS 16. The deadline remains open until 22 April 2024. The UK Endorsement Board has announced some outreach activities to understand UK stakeholder views on IASB’s Exposure Draft Business Combinations – Disclosures, Goodwill and Impairment. The FRC has published its Plan and Budget for 2024-25, outlining its aims for a year of consolidation and prioritisation to support public interest outcomes and UK economic growth. The UK Government has announced its plans to legislate following its non-financial reporting review. The planned measures include a planned increase to the company size thresholds by approximately 50%, as well as other measures designed to streamline and improve reporting requirements. The FRC has welcomed the announcement. The IFRS National Standard Setters March 2024 Newsletter has been issued which features details on the upcoming 2024 World Standard Setters Conference in London and ISSB recent highlights. Auditing IAASA has issued a revised version of ISA (Ireland) 505 – External Confirmations. The main changes to the standard relate to: Clarification on what constitutes an electronic external confirmation. Prohibition on the use of negative external confirmations. Strengthened link with ISA (Ireland) 330 The Auditor’s Responses to Assessed Risks. Enhanced requirements concerning the investigation of exceptions. The revised standard is effective for audits of financial statements for periods beginning on or after 15 December 2024, with early adoption permitted. The revised ISA (Ireland) 505 is available here. Anti–money laundering and sanctions We have recently prepared an information booklet entitled The Economic Crime and Corporate Transparency Act 2023 – Changes in Companies House outlining the first set of changes introduced by Companies House on 4 March 2024. The Economic Crime and Corporate Transparency Act gives Companies House, along with the Registrar of Companies for Scotland and the Registrar of Companies for Northern Ireland, the power to play a more significant role in tackling economic crime and supporting economic growth. Over time, its measures will lead to improved transparency and more accurate and trusted information on its registers. The Dept. Of Justice has recently published Guidelines for Designated Persons supervised by its Anti-Money Laundering Compliance Unit (AMCLU). The purpose of the Guidelines is to assist those Designated Persons supervised by the AMLCU in understanding and meeting their Anti-Money Laundering and Countering the Financing of Terrorism obligations under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 as amended and related Statutory Instruments. Please click here for a press release with some further details. Insolvency The CCAB-I Insolvency Committee has recently published Technical Alert - Cross Border Insolvency and Brexit. This Technical Alert considers the impact of Brexit on both the recognition of Irish Insolvency proceedings in the UK and the recognition of UK Insolvency proceedings in Ireland. Sustainability The International Sustainability Standards Board (ISSB) has issued an update on the jurisdictional progress made in adopting the IFRS Sustainability Disclosure Standards. This includes details of the countries who are consulting on their adoption, as well as those who have completed their jurisdictional consultations. The ISSB has issued its March 2024 update and podcast. The FRC has announced the launch of its first market study to examine the UK market for sustainability assurance services. The study aims to ensure this rapidly growing market is functioning effectively and providing high quality assurance over companies' sustainability reporting. The GRI has published three new guidance documents to support global policymakers. These documents cover Double Materiality, Due Diligence and the CSRD. The Ministers for Finance and for Public Expenditure recently published the Future Ireland Fund and Infrastructure, Climate and Nature Fund Bill 2024. The Bill will provide for the establishment of the two funds in its title. One is the Future Ireland Fund which is for the purpose of supporting State future expenditure pressures including ageing, climate, digitalisation and other fiscal and economic challenges in a consistent and sustainable manner from 2041 onwards. The other is the Infrastructure, Climate and Nature Fund which is for the purpose of supporting State expenditure, in 2026 or any year after that to assist with climate change objectives and nature, water quality and biodiversity issues. The Fund will provide for resources for spending in a future downturn to support expenditure through the economic and fiscal cycle and to support designated environmental projects. Please click here for a press release on the Future Ireland Fund and Infrastructure, Climate and Nature Fund Bill 2024 which provides further information. Other news The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has published its third consultation package under the Markets in Crypto-Assets Regulation (MiCA). As part of the Financial Reporting Council (FRC)’s review of the UK Stewardship Code 2020, a series of roundtable discussions are being held on the efficacy of the 2020 Code in order to receive feedback on areas for potential improvement and the extent to which the Code continues to meet its stated purpose.  These discussions will run from 26 March to 7 May. The FRC and the Australian Securities and Investment Commission (ASIC) have announced a Memorandum of Understanding on Reciprocal Arrangements (MOURA) making it easier for auditors to work between both countries. The UK’s Financial Intelligence Unit has issued the 25th edition of its SARs in Action magazine which focusses on the Illegal Wildlife Trade. Powering Prosperity – Ireland’s Offshore Wind Industrial Strategy, is the first strategy of its kind for Ireland which aims to build a successful and impactful offshore wind energy industry.  It was developed as part of close ongoing collaboration between the Department of Enterprise, Trade and Employment and other government departments and agencies within the Offshore Wind Delivery Taskforce (OWDT). Proposed new company law provisions The Department of Enterprise, Trade and Employment published the General Scheme of Companies (Corporate Governance, Enforcement and Regulatory Provisions) Bill 2024 on 15 March 2024. The General Scheme proposes wide ranging changes to the Companies Act 2014. Changes which may be of interest to readers include a change to loss of audit exemption, receiverships, SCARP and winding up, three new grounds for involuntary strike off, changes for Corporate Enforcement Authority and provisions relating to IAASA. You can click here to read an Institute news item giving more detail about the proposed changes. Corporate Enforcement Authority Readers can also find more detailed information on changes that the Companies (Corporate Governance, Enforcement and Regulatory Provisions) Bill 2024 proposes for the Corporate Enforcement Authority (CEA) in the CEA’s recently published  information note and press statement. For further technical information and updates please visit the Technical Hub on the Institute website.      This information is provided as resources and information only and nothing in the information 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 information. 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 the information 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 herein.    

Following constructive engagement with Government departments, the Institute has secured a change which should make the process of hiring non-EEA accountants by way of a Critical Skills Employment Permit (CSEP) less burdensome. In recent months, member firms have reported to us a significant increase in the need to apply for bridging CSEP visas for their workers while their residency status is being processed.  New rules announced this week should substantially reduce this requirement. CSEP’s are valid for a period of two years, after which employees holding this permit can typically go on to apply for continued residence in Ireland under what is known as a Stamp 4. Since November 2023, in order to secure a Stamp 4, the holder of a CSEP was required to complete a minimum of 21-months' work following the issuance of a Stamp 1 (a permission to work visa). Delays in issuing a Stamp 1 meant that member firms have had to apply for bridging CSEPs because the 2-year CSEP would expire before accountants could meet the 21-month work requirement. Amplifying our members concerns, we called for a reinstatement of the previous system whereby a Stamp 4 could be secured 21 months from the commencement of employment in the State - rather than from the commencement of a Stamp 1. Following a sustained period of engagement with department officials, this suggestion was formally adopted by the Department of Justice with immediate effect – details of the changes can be found here. Chartered accountants are currently listed on the Government’s Critical Skills Occupations List – meaning that due to capacity shortages in the industry, suitable candidates from non-EEA jurisdictions are eligible to apply for a Critical Skills Employment Permit (CSEP) to come and work in the profession here. The Department of Enterprise, Trade and Employment and the Department of Justice have jurisdiction over the issuance of CSEP’s and Stamp 4 residence permits. Further information on CSEPs can be found here on gov.ie. The previous changes announced by the Department of Enterprise, Trade and Employment (DETE) on November 15 2023 can be found here. Should you have an issue which you would like to bring to the attention of the public policy team, please reach out via our email publicpolicy@charteredaccountants.ie

The CCAB-I Insolvency Committee has recently published Technical Alert - Cross Border Insolvency and Brexit. This Technical Alert considers the impact of Brexit on both the recognition of Irish Insolvency proceedings in the UK and the recognition of UK Insolvency proceedings in Ireland.

Julia Rowan answers your management, leadership and team development questions Q. I manage a team of four people in a large organisation. Up until recently, we all got on and worked well together. However, the mood has changed. The work is getting done, and everyone is polite, but I am being shut out. I think this is in response to company-wide changes during which we lost a popular team member. I had no control over this. A. One of the key things leaders do is act as a buffer between the hard shell of the organisation – with its policies, structures and procedures – and the social and emotional needs of individuals. It is a tough gig.  Right now, it sounds like your team is angry with the organisation. Sadly, they are not going to tackle the CEO, so you are getting the flack. When change is perceived negatively, there is a lot of blame. Leaders often get sucked into explaining, defending and rationalising – which only makes things worse. In reality, people are frightened and worried. They are wondering, ‘Can I cope with the changes?’, ‘Will I be next?’ They are placing blame at your feet to hold those fears at bay. While you may be unable to control the changes your company decides to make, you can help your team to navigate them.  Allow people to air their fears – and listen without judgement. Underneath it all, your team does not blame you. They understand that changes need to be made to keep organisations competitive. When you listen, people will start talking about what is important to them, and this is where you can have a connected conversation. I suggest you raise this issue at a team meeting. Say that you have noticed a change in the team mood and feel it would be useful to discuss this in one-to-ones or at the next team meeting.  If people bring up the issues, connect with them where they are. Prepare to listen and absorb. You might have to listen to a rant – at the end of a rant, there is often an apology and an acceptance of the need to move on.  When the time is right, agreeing on how to move forward may be useful. Have some ‘connecting’ questions ready, for example: What is important for you/the team? What could I/we have done differently? What do you want from me/from each other at this time? What can I help you with?  How do we support each other? How do we want to move forward? Finally, it may be important to look at how your team member left. Did you and the team get a chance to mark that properly? If not, the team may like to fix that. Julia Rowan is Principal Consultant with Performance Matters Ltd, a leadership and team development consultancy. To send a question to Julia, email julia@performancematters.ie

Three Chartered Accountants tell us how they use performance metrics to enhance organisational efficiency beyond traditional benchmarks Niamh McCarthy Finance Business Partner Primark Relying solely on Key Performance Indicators (KPIs) can mean ignoring the human elements that impact performance. Focusing only on a project’s outcomes might meet KPIs, but it can also make people feel that their wellbeing or personal development is not a priority. In my experience, the best way to ensure a balance between quantitative metrics and qualitative assessments is to set clear expectations when setting annual goals, provide feedback and coaching more regularly than in one-off annual reviews so that everyone is aligned, and add weighting to both quantitative and qualitative metrics based on their importance to the company.  Subjective factors such as employee behaviour, teamwork and communication skills are crucial in performance evaluations.  These measures can influence a company’s culture as employees feel heard and that they can collaborate with their peers. These positive behaviours drive a positive culture. The more positive employees feel, the more productive they tend to be.  Careful consideration is required before implementing alternative performance measures to ensure clear definitions of the metrics. Transparency is a must to ensure everyone understands the metrics that are being used.  A standardised approach is also needed for all employees. To achieve this, the managers setting these performance measures need adequate and uniform training to ensure consistency for everyone.  Employees should be involved in their goal-setting every year, of these goals must align with the company’s values and objectives. There should be a sense of ownership over these so that they are not just ‘given’ to the employee but they instead feel that they have created them, can drive them and ultimately achieve them.  These goals should be reviewed regularly – not just annually – to ensure that they are still relevant. Otherwise, you risk employees feeling disconnected from their own objectives or those of the business.  Unlike traditional performance metrics focused solely on quantitative outputs, alternative performance measurement methods often take a more holistic approach.  Various factors are considered, such as skills, behaviours, contribution to the team and alignment with company values. This comprehensive assessment provides employees with a more nuanced understanding of their strengths and potential areas for improvement, facilitating targeted development efforts.  Employees who feel they can grow and develop within a company are more likely to actively contribute to the business. The more you give back to employees in terms of recognising their development and wellbeing, the more they will give back in turn. Mark Riseley Strategic and Financial Consultant/Fractional CFO My lens is formed from a career working for high-growth scale-ups where change is constant, requiring systems, data, processes and (most importantly) people to flex as the company grows.  Traditional KPIs are often unsuited to measuring capacity to scale efficiently, for both people and companies, and do not capture a company’s true enterprise value along that path. Some alternate measures of performance include: Time management – In high-growth environments, time may be a team’s most valuable commodity. Does the company measure time, quantity and output generated by meetings?  Data – What is high-quality data, and what is just noise? Instead of just measuring data output, measure the speed and efficiency of decisions to determine which data is worth keeping. Adaptability to a culture of change – Identify, hire and measure based on key personality traits, such as decision-making capacity, adaptability/flexibility, resilience, trust, diligence and communication skills, rather than just the known skills of the profession. Effectiveness of organisational design – Is the organisation’s design scalable, or does it need to pivot to enable growth? Does it allow executives to delegate/empower decision-making? Check employee turnover to determine the effectiveness of your organisation’s outlay. Common goal – Is the common goal clear? Do companies measure the clarity of messaging, such as doing spot checks on the elevator pitch, for example? Do performance measures flow from the corporate to departmental and individual level? Make sure all messaging is aligned. Enterprise value – Is enterprise value (EV) clear, measured and reported? Is there a consequence to hitting forecasts? The ability to do this can mean the difference between a rear-view EV and a front-view EV. Are margins increasing, thereby demonstrating the effectiveness of scaling systems, processes and people? To ensure that alternative performance measures align with organisational goals and contribute to overall success, companies must clearly define their goals, objectives and values so that employees fully understand and can align them with their own goals, objectives and values.  Alignment and collaboration between different departments and teams within the organisation will ensure alternative performance measures are consistent and mutually reinforcing. Success is more likely if all employees feel they are working towards a common goal aligned with the company’s goals.  Yier Hu Senior Associate in Management Consulting KPMG   There are certain limitations to relying solely on KPIs for performance measurement. Although KPIs provide quantitative metrics to measure performance, they tend to overlook crucial perspectives essential for a comprehensive evaluation.  At KPMG, we recognise the importance of looking beyond KPIs to ensure a thorough approach to performance measurement. The quantitative matrix can fail to account for a series of subjective factors, such as employee behaviour and communication skills. These intangible elements offer valuable insights into employee performance and should be considered alongside quantitative measures. KPMG employs its own separate benchmark for performance measurement, analysing performance from six distinct perspectives: client, people, innovation, financial strength, public trust, quality and development. We advocate for measuring performance from multiple perspectives, recognising the importance of a holistic approach. These alternative measurements assess the benefits an employee brings to clients while also evaluating their contributions to the working environment.  From the people perspective, we focus on how the team studies and improves, how to be a strong mentor to the team, how to build internal communication and culture and how to make everyone feel like a part of the team.  From an innovation perspective, we prioritise building trust with the team and client, supporting the team to identify opportunities, and leading by example. This is crucial and creates long-term value while also enhancing overall satisfaction within the company.  By embracing a multi-dimensional approach to performance measurement, organisations can gain a more nuanced understanding of their employees’ contributions and foster a culture of continuous improvement and growth.

Growing support for extremist and smaller parties across Europe could change the fundamental composition of the new European Parliament, writes Judy Dempsey Elections to the European Parliament (EP) take place every five years. Until recently, the outcomes were predictable. The conservative European People’s Party has dominated with the Progressive Alliance of Socialists, albeit with declining numbers, and Democrats (S&D) coming in second.  Their decline reflects waning support for mainstream parties and an increasing fragmentation of European party systems at national and European levels.  This time round, the EP election is about how the growing support for extremist and smaller parties across Europe could change the composition of the parliament and the EU. Integration is taking a back seat. The European Council on Foreign Relations (ECFR) reckons the major winner in the EP elections will be the radical right Identity and Democracy (ID) group.  “We expect it to gain 40 seats and, with almost 100 MEPs, to emerge as the third largest group in the new parliament,” states ECFR.  The political elites across Europe are nervous as far-right parties in France, Germany, Austria, Portugal, Hungary, Italy and other countries are campaigning hard to strengthen their presence in the EP. And, despite backroom deals and trade-offs taking place inside the EP regarding which countries will become EU commissioners, a different political constellation could upset the way things have been done in the past. The political status quo across Europe is changing. The 2009 global financial crisis dented the belief that the EU was on a permanent trajectory towards prosperity. The wars in Syria that led to well over a million people seeking refuge in Europe in 2015 created divisions inside the EU regarding identity and values. COVID-19 and Russia’s war in Ukraine dented the unity and self-confidence of the EU even further.  More importantly, as EU leaders grapple with these global issues, they must respond to their electorates back home.  Citizens want security, affordable housing, better access to good schools, healthcare and other public services. These services are under pressure as governments, struggling with inflation, weigh up the cost of spending or saving more.  The far-right, nationalist and far-left parties, from the comfort of not being in office, exploit these crises. They want their governments to stop sending weapons to Ukraine; to stop the inflows of asylum seeks or refugees fleeing wars, famine and the effects of climate change. They question the costs of protecting the environment.  In short, the sense of security that characterised most of (Western) Europe after 1945, and even after the reunification of Germany after 1991, is being replaced with an uncertainty that populist and far-right and far-left parties are tapping into.  They challenge the status quo that oversaw the establishment of today’s EU.    If they gain many seats in the EP, they will not want to leave the EU. The financial benefits are too big and support for the EU is still high across the bloc. Instead, they want to change the EU from within.  The issue for these parties is sovereignty. Like Brexit, they want to ‘regain’ their national sovereignty but remain in the EU.  Yet EU membership requires ceding some sovereignty in return for certain benefits. With few exceptions, EU leaders shy from selling those benefits to their citizens. Their reluctance plays into the hands of the far right and the far left.   Judy Dempsey is a Non-Resident Senior Fellow at Carnegie Europe and Editor-in-Chief of Strategic Europe

Patrick Gorry delves into the findings of the European Commission’s Market Monitoring Report and revisits the broader context and impact of EU audit reform On 5 March 2024, the European Commission published its triennial Market Monitoring Report, analysing Public Interest Entity (PIE) audit data from 2019 to 2021 across 27 Member States as well as Norway.  A decade after the enactment of European Union (EU) audit reform legislation, the report underscores the persistent market dominance of the main firms in PIE audits, resulting in limited choices for auditors. Background and objectives of EU audit reform The introduction of EU audit reform stemmed from several key drivers and broader contextual factors.  Amidst the global financial crisis of 2008, weaknesses in financial reporting and corporate governance practices were exposed, prompting the EU to prioritise enhancing the integrity and transparency of audit processes.  In 2014, the EU adopted two legislative instruments: Directive 2014/56/EU, which amended Directive 2006/43/EC on the statutory audits of annual accounts and consolidated accounts (the Audit Directive), and Regulation No. 537/2014 on specific requirements regarding the statutory audit of PIEs (the Audit Regulation).  The legislation was led by several key EU institutions, including the EU Commission, EU Parliament, EU Council, European Securities and Marketing Authority (ESMA) and national regulatory authorities in EU Member States.  While the overarching goal was to increase the quality of statutory audits, the four primary objectives set out for the reform were to: Reinforce auditor independence; Promote market competition; Enhance transparency for investors; and Strengthen pan-European supervision. Measurement of success  To evaluate the legislation’s effectiveness, we must examine each objective. Reinforcing auditor independence The legislation mandates the rotation of audit firms for PIEs after a specified period to help address familiarity and independence issues, promote fresh perspectives and improve audit objectivity.  It also restricts audit firms from providing certain non-audit services to their audit clients and imposed limits on fees for such services.  These measures aim to promote independence, prevent conflicts of interest and uphold audit integrity. The legislation has strengthened auditor independence by enforcing mandatory rotation for auditors of PIEs. This has reduced conflicts of interest and enhanced audit objectivity.  Stricter rules regarding non-audit service provision have further bolstered auditor independence, ensuring a focus on high-quality audit services. Mandatory rotation has, however, faced criticism for potential unintended consequences, such as increased costs for companies and concerns about the disruption of longstanding audit relationships.  The Market Monitoring Report revealed limited choice in tenders within the EU audit sector: 16 percent of the tenders had just one bid and 59 percent left PIEs with a limited choice of two to three bids.   In the same report, 51 percent of surveyed audit committees that had undergone auditor changes indicated that it was too early to evaluate the impact of auditor rotation or that no assessment had been made at the time the Commission issued the questionnaire.  Furthermore, 22 percent of audit committees rated the impact of auditor rotation as ‘neutral’, while 12 percent rated it ‘positive’. Promoting market competition The legislation aims to promote market competition and diversity in the audit sector by encouraging smaller audit firms to participate in PIE audits. It is meant to drive innovation, enhance audit quality and offer clients a broader selection of service providers. To achieve this, the legislation mandates regular rotation or tendering of audit engagements to stimulate competition.  It also promotes joint audits to facilitate smaller firms’ involvement and enhance market competition.  Additionally, the legislation aims to increase transparency in the audit market by publishing data on audit firm market share and concentration. Despite these efforts, market concentration remains a challenge. Larger firms continue to dominate, limiting the entry of smaller firms and hindering diversity among service providers.  While the largest firms’ dominance in the number of PIE audits has fallen slightly, they still control a significant portion of the market from a fee perspective.  Interestingly, a growing demand for joint audits indicates a potential shift in the market landscape toward increased diversity. The Market Monitoring Report highlighted the continuing imbalance: In terms of total turnover among audit firms, the largest four firms collectively accounted for approximately 80 percent of the market, consistent with previous reports from the European Commission. Despite a decline in their share of PIE audits, these firms still hold a dominant position, capturing 86 percent of revenue from this source.   Joint audits now account for 16 percent of the PIE market, up from nine percent in 2018. This trend is evident across an increasing number of Member States, with five additional countries adopting joint audits since 2018, bringing the total to 13. Among the six Member States with the most diversified PIE audit markets, joint audits are prevalent in five: France, Romania, Bulgaria, Poland and Greece. The findings relating to European market concentration are replicated in the Irish market. The Irish Auditing and Accounting Supervisory Authority’s most recently published Annual Audit Programme and Activity Report put the market share of the four largest firms at 87 percent.  Enhancing transparency for investors The legislation mandates increased audit reporting transparency, requiring additional information disclosure.  This increased transparency aims to improve communication between auditors, clients and stakeholders, providing a more comprehensive view of the audit process. The new rules have significantly improved the informational value of audit reports, which is a key success of the legislation.  The mandates have improved communication between auditors, clients and stakeholders, ensuring investors can access relevant information to make informed decisions.  However, challenges remain in effectively communicating audit findings to investors. Discussions are ongoing concerning further enhancements to meet the investors’ evolving needs.  Strengthening pan-European supervision The reform introduced measures to enhance governance and oversight of audit firms, including establishing regulatory bodies and oversight mechanisms to monitor compliance with audit standards. The objective was to improve the consistency and effectiveness of audit supervision across Europe. The legislation has undoubtedly increased cross-border cooperation and information sharing among national competent authorities.  Harmonising audit standards and practices across Member States has aligned regulatory requirements, fostering a unified framework for audit supervision while improving quality and consistency at the European level. However, one of the main challenges of strengthening pan-European supervision is the divergence in implementation of the audit regulation and oversight practices across Member States. Future audit reform EU audit reform represents progress, but there’s still work ahead. While successes are evident, challenges persist, notably the dominance of major audit firms. The 2022 EU Commission study on the impact of the audit reform highlights improvements in harmonising national frameworks. However, it underscores lingering disparities in the transposition, implementation and enforcement of EU audit legislation across countries. The legislation has profoundly impacted audit firms and the profession by reshaping regulatory requirements and enhancing independence, quality standards and transparency within the EU.  Yet, ongoing evaluation is necessary to ensure continued progress in the improvement audit quality, transparency and governance. Recent high-profile accounting scandals, such as the Wirecard bankruptcy in Germany, underscore the need for further reform, especially amid increasing demand for sustainability reporting and digital audits.  With a new EU Commission and Parliament taking office imminently, however, further legislative developments are unlikely in the near term.  On the other hand, the Market Monitoring Report identifies potential challenges, including inflationary pressures, rising interest rates, geopolitical instability and the growing use of data analysis tools and artificial intelligence, which will require attention sooner or later.  One thing appears certain – what audit will look like in another 10 years will dramatically differ from what it looks like today. Whether an EU Audit Reform 2.0 is one of key change drivers remains to be seen. Patrick Gorry is a Partner in the Audit and Assurance Financial Services Group of Mazars Ireland