The Philippines has joined the OECD/G20 Inclusive Framework on BEPS and has committed to addressing the tax challenges arising from the digitalisation of the economy by participating in the Two-Pillar Solution to ensure that multinational enterprises pay a fair share of tax in the jurisdictions in which they operate.  

Last week, Ireland joined its international partners in welcoming the new international standard, developed by the OECD, on the automatic exchange of crypto information between tax authorities. The Crypto Asset Reporting Framework is being delivered within the EU through an amendment to the Directive on Administrative Co-Operation.   A publication by the Irish government states that “Ireland is already a recognised global leader in exchange of information and today marks an important staging post which reinforces Ireland's commitment to best international practice in tax transparency.”  Read the joint statement.  

Last week the Institute was represented at meetings in London of the UK Domestic Advisory Group (“DAG”), and at the annual joint UK and EU DAG meeting. After the joint meeting with the EU, a statement was issued by the UK and EU DAG’s setting out the matters discussed in more detail. On day two, representatives from both DAGs and from civil society were present at the annual Civil Society forum which provided an opportunity to feedback to representatives of the UK Government and the European Commission on key issues and concerns in implementing the Trade and Co-operation agreement.  The UK DAG is conducting its work via the following sub-groups each of which aims to publish on GOV.UK an update on key issues being discussed in the near future:-  Business and Labour Mobility;  Trade and Customs;  Regulatory Cooperation and Level Playing Field;  Energy and Climate Change; and  Nations and Regions.  Chartered Accountants Ireland participates in the Nations and Regions sub-group and was in attendance at the most recent meeting of this sub-group which took place in Edinburgh on Friday 10 November. During this meeting, attendees heard from Dimitris Dimitriadis, President of the European Economic and Social Committee’s External Relations Section as well as Irene Oldfather Vice-Chair of the UK DAG and Chair of the Sottish Advisory Forum on Europe. Broadly, concerns about youth mobility, environmental targets and the need for clearer guidance on business and economic issues were heard.    During the UK DAG meeting, attendees heard from Professor Anand Menon (UK in a Changing Europe) about the 2026 TCA review process and what that might look like given the potential for a change in UK Government after the next election. Sir Oliver Heald, Leader of the Delegation and Co-Chair of the UK-EU Parliamentary Partnership Assembly, was also in attendance and listened to various concerns from the UK DAG’s sub-groups.  Last week’s meetings in London took place in the grand surroundings of Lancaster House (see photo) which has been used in previous series of Netflix’s The Crown and which also features in the final series starting later this week. The UK Government’s wine cellars are also located at Lancaster House. 

In early October, the Institute responded to the House of Lords Finance Bill Sub-Committee’s inquiry into draft Finance Bill 2023/24. As the Committee has now accepted this as evidence, the submission is available to read in the Tax Representations section of our website. The Institute’s submission was focused on two specific areas of concern in the draft Finance Bill:- The proposal to restrict the geographical scope of agricultural property relief and woodlands relief for inheritance tax to UK land and property only from 6 April 2024 – in August the Institute wrote to the Financial Secretary to the Treasury on the same issue; and  The proposal to potentially merge the UK’s SME and “large” company R&D tax relief regimes from 1 April 2024.    You can read the Institute’s recommendations in relation to both of these areas in the submission. 

In this week’s EU exit corner, we bring you the latest guidance updates and publications relevant to EU exit. The latest Trader Support Service bulletin is also available in addition to the most recent Cabinet Office Borders bulletin which recently returned from a break. The Minister of State has written to the Chair of the House of Lords Protocol Sub-Committee providing an update the on the implementation of the Windsor Framework (“WF”) and this Committee has recently launched a new inquiry into regulatory divergence and the WF. Miscellaneous updated guidance etc.   The following updated guidance, and publications relevant to EU exit are available:-  Check if a business holds Authorised Economic Operator status;  Apply to use Simplified Import VAT Accounting;  CDS Declaration Completion Instructions for Exports;  Split consignments: Tariff classification and import procedures;  Known error workarounds for the Customs Declaration Service (CDS);  Apply for an Advance Tariff Ruling;  Data Element 2/3 Documents and Other Reference Codes (National) of the Customs Declaration Service (CDS);  Additional Information (AI) Statement Codes for Data Element 2/2 of the Customs Declaration Service (CDS);  Customs Declaration Completion Requirements for The Northern Ireland Protocol;  Customs Declaration Service (CDS) waiver codes for imports replacing 999L;  Authorisation type codes for Data Element 3/39 of the Customs Declaration Service; and Split consignments: Tariff classification and import procedures.

HMRC recently continued its communication campaign on Pillar 2. In the UK, Pillar 2 will have effect in respect of in-scope groups’ accounting periods beginning on or after 31 December 2023. Letters to businesses are being sent to the Large Business (“LB”) population in addition to Wealthy and Mid-sized Business (“WMB”) taxpayers. The continuation of the communication campaign also includes letters to agent representatives, and articles in both the November 2023 Agent Update and HMRC Stakeholder Digest.   According to HMRC, steps have been taken to expand the avenues which correspondence is being issued to and HMRC is also encouraging potentially affected taxpayers to sign up to receive digital correspondence in future if they have not already done so.  The specific activity being undertaken commenced at the end of last month and is as follows:-  From Monday 30 October, letters began to issue to LB taxpayers that had not signed up to receive email updates;  From Friday 3 November, a bulk email was then issued to LB and WMB taxpayers, and to agents and representatives bodies who had signed up to receive email updates;  From Monday 6 November, letters began to issue to any remaining WMB taxpayers who had not previously signed up. 

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.  

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.  

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. 

Seasonal corporate gifting is standard in business but can it be done responsibly? Feena Kickhamm outlines her advice on sustainable gift-giving for Irish businesses this Christmas Sustainable corporate gifting is an excellent opportunity to demonstrate a company’s sustainability commitments, including environmental and social responsibility. Businesses can inspire their employees, build a positive brand image, and contribute to a better world by choosing sustainable gifts. There are several issues to bear in mind when trying to keep your gifting green. Define your values: Clarify the criteria most important for your corporate gifts, e.g. environmental impact, supporting local communities or fair trade. Local sourcing: Support local SMEs and social enterprises. This supports the local economy and reduces carbon emissions from shipping. Eco-friendly materials: Choose gifts with a good environmental footprint, such as made from recycled or upcycled materials and consider reusable or recyclable packaging.   Education: Raise awareness with information about the sustainability and ethics of your chosen gift to recipients.   There is a wealth of small, creative, and sustainable businesses to choose from in Ireland. Here are several that are worthy of your support this holiday season: Social Enterprises We Make Good has products that are designed by some of Ireland’s best designers and made by people facing social challenges who have been supported to develop valuable skills and gain employment.   Rediscovery Centre is an eco store providing a wide range of upcycled and reused circular economy products.   ReThink Ireland contains a directory listing social enterprises you can support in Ireland.   Going green Ireland currently recycles 31 percent of all plastics, which needs to increase to 50 percent by 2025 under EU Legislation. There are shops that can help us reach this goal. Reuzi, Faerly, and Pax are just some of the zero-waste businesses in Ireland providing a range of gifting solutions to encourage minimal-waste living.  Jimmy Eco Toys is a toy company retailing and distributing eco-friendly toys. Hometree plants native woodland in Ireland to help with land regeneration and biodiversity. You can pledge or donate for trees planted in Ireland.  Of course, you can also give e-gift cards, experience gifts or donations to a local charity to guarantee your gift doesn’t end up in a landfill. Ethical food Coffee and chocolate production are often linked to environmental and human rights challenges, but there are many companies actively working to overcome these issues. Moyee Coffee offers fair chain coffee, meaning more value stays in coffee-growing countries through the creation of quality employment and provision a living income for farmers. Tony's Chocolonely is a Dutch chocolate brand committed to eradicating child labour in the global chocolate supply chain.   Imbibe Coffee is organic, socially conscious coffee that is giving back. One percent of its coffee sales go to Women’s Aid, one percent to projects at coffee origins they buy from and a further one percent is shared among its staff.  Making the effort Sourcing sustainable and ethical corporate gifts may take time and have a slightly higher upfront cost, but it demonstrates your commitment to responsible business practices and can have a real positive impact on smaller businesses.   We recognise there are many more great small businesses and social enterprises not listed here, and we encourage companies to expand their corporate gifting search a little this year to support as many as possible. Feena Kickhamm is Sustainability Adviser at Business in the Community Ireland 

As the winter sets in and temperatures drop, your staff may become more vulnerable to illness. Gemma O’Connor explains how to help reduce the spread of infection in your workplace While you can’t stop staff from getting sick, you can take steps to lower the risk of employee illness impacting your operations. The following steps can help keep your business up and running all winter. Clamp down on presenteeism While absenteeism causes its own problems, it’s a good idea to let staff know that it is okay to be ill. Many employees continue going to work while they’re unwell and infectious out of fear that not turning up will have a negative impact on their prospects with the organisation. This “presenteeism” (i.e. the pressure to be present at work) can be very damaging for you and your employee, however. Employees who continue working while ill will likely struggle to perform, prolong their illness, and pass it on to others. So, while you don’t have to manage without an absent employee in the short term, you could end up having more people off work sick in the weeks following their illness. Ventilate your workplace As a general rule, you should make sure your workplace is well-ventilated – especially in enclosed areas. If your staff work in a poorly ventilated enclosed space, it’s far more likely that infectious illnesses will spread. Ensuring your workplace has access to fresh air will help reduce the transmission risk. If you can’t open windows, you should have an air conditioner installed. The Health and Safety Authority has recently released a Code of Practice for Indoor Air Quality that goes into greater detail on how to maintain acceptable indoor humidity levels. Encourage staff to maintain a clean working environment Maintaining good hygiene practices at work will also help to reduce the risk of viruses spreading. It’s important to remind staff to be responsible for their hygiene by washing hands, covering their mouths when sneezing or coughing, and keeping surfaces clean. You could put signs around the office to remind staff to practise good hygiene, leave hand sanitiser on desks or provide a communal sanitiser, and offer protective equipment to staff. Review your sickness and absence policy If you don’t currently have a sickness and absence policy, you must set one up to comply with the Sick Leave Act 2022. Whether you have a standalone policy for sickness – or one policy outlining how you deal with all types of absences – it’s essential to have it in writing and to communicate it to staff. Having a policy gives you and your staff a process to follow if they think they might not be well enough to work. In your policy, you should outline: how to report a sickness absence; how often you’ll be in touch while your employee is off work; how you support employees who are returning to work after a sickness absence; and your statutory sick pay policy as required under the Sick Leave Act 2022. For 2023, your staff have a statutory entitlement to three days of paid sick leave. This entitlement is scheduled to increase to five days of paid sick leave in 2024. Your sick leave policy should set out the minimum payments for periods of certified sick leave, which is 70 percent of the employee’s usual daily earnings up to a maximum of €110 a day. Gemma O’Connor is Head of Service at Peninsula Ireland

Brexit has been with us for quite some time, yet challenges remain for businesses trading with the UK. Janette Maxwell outlines the practical considerations for Irish importers and exporters Recent CSO figures show imports from Britain to Ireland fell by 14 percent to €1.8 billion in August 2023 compared to August 2022, and exports from Ireland to Britain fell by 15 percent to €1.3 billion in August 2023 compared to August 2022. With imports and exports in decline, it’s hard not to look to Brexit and the challenges it has brought as the culprit. Here are some practicalities to consider when trading with Britain. Irish-based businesses unwilling to act as importers of record Where an Irish-based business sources goods from outside the EU, it may not be willing to take on the responsibilities associated with the importation. To secure these sales, the foreign supplier seeks an Irish VAT registration and an EU Economic Operators Registration and Identification (EORI) number to act as the importer of record on the basis the sales are subject to the incoterm, delivered duty paid. The foreign supplier is then responsible for the importation of the goods into Ireland and pays the import VAT and any customs duty arising from the importation. The subsequent sale of the goods by the foreign supplier is subject to Irish VAT, which is returned on the foreign supplier’s Irish VAT return, with the import VAT being claimed as input VAT. Subject to authorisation from the Irish Revenue, it may be possible for the foreign supplier to use postponed VAT accounting for the imports. Postponed VAT accounting for imports An Irish VAT-registered business may apply to the Irish Revenue for authorisation to use postponed accounting for imports. Where this is granted, an importer does not pay import VAT on the clearing of the goods through customs. Instead, the import VAT is included as output VAT in the Irish VAT return, with the importer claiming input VAT in the same return subject to the deductibility provisions. There is a requirement to include the customs value of the goods in the PA1 field of the VAT return and in the appropriate fields of the annual return of trading details, i.e. PA2 and PA3 or PA4. EORI numbers A business acting as the declarant when importing or exporting goods from the EU must have an  EORI number, enabling the EU Customs administrations to deal with customs-related procedures. An Irish-established business can obtain its EORI by applying to the Irish Revenue. However, a non-EU established business should request its EORI from the EU member state in which it first lodges a customs declaration or applies for a customs decision. Contracts that would result in a UK VAT registration obligation Should the Irish business sell goods on delivered duty paid (DDP) terms to a customer in Britain, the Irish business would have to deal with the importation of goods into Britain. Where DDP terms apply, the Irish business must appoint a UK-established agent and obtain a British EORI number. The Irish company would also have to register for UK VAT to pay over the UK import VAT arising and to charge UK VAT on the domestic supply of the goods to the customers in Britain. Postponing the UK import VAT Import VAT is typically payable at the point of importation into Britain. UK import VAT is liable on goods at the same rate which would apply to the goods had the supply occurred in the UK – i.e. 20 percent.   Like Ireland, the UK government introduced a measure allowing importers to operate a postponed method of accounting for the UK VAT. This means that the payment of import VAT can be delayed until the next VAT return following the date of importation. The Irish business would self-account for import UK VAT and – subject to the standard VAT recovery rules in the UK and its VAT recovery entitlement – would be entitled to claim a corresponding VAT deduction, potentially providing a cash-neutral position for the Irish business. It is important to remember that customs duty may also arise, which is non-recoverable and represents an absolute cost for the business. What’s ahead At the contract negotiation stage, it is vital that the Irish business understands the impact of the commercial terms to which they are agreeing and, if possible, negotiates more favourable terms which may avoid a UK VAT registration and the associated registration and compliance responsibilities. It is also essential to keep up to date with VAT legislative developments in the UK and seek UK VAT advice as required, in addition to Irish VAT advice. Janette Maxwell is a Director of Tax with Grant Thornton Ireland

The Economic Crime (Transparency and Enforcement) Act 2022 created the Register of Overseas Entities (ROE). It requires overseas entities owning UK property to reveal their beneficial owners and to register their entities on a publicly available register.  Information must be verified before an overseas entity makes an application for registration, complies with the updating duty or makes an application for removal. The Register of Overseas Entities (Verification and Provision of Information ) Regulations 2022 (SI 2022/725) set out the details of the verification system. The drafting of the Verification Regulations means that there is a strict liability in place and the accountancy professional body supervisors are concerned that any firm acting as a verifier will face significant challenges and expose itself to significant risk, including possible criminal prosecution, regulatory sanction, and reputational damage. Firms should carefully consider whether they should provide this verification work. The work required for verification under the ROE is not the same as the risk-based approach to client due diligence under Money Laundering Regulations 2017 and firms should familiarise themselves with the differences. The Government has produced further Guidance to assist. The Accountancy AML Supervisors Group (AASG) published an AML Alert highlighting key risks associated with this work. The Institute has previously shared this AASG AML Alert on ROE-Verification work with the MLCPs and MLROs but would highlight again the risks associated with this verification work.

The OECD has published the latest edition of Revenue Statistics in Africa. The publication pulls together tax revenue and non-tax revenue statistics from 33 African countries. The report enables comparison not only between the countries covered in the report, but also with the OECD and other regions.

The African Tax Administration Forum (ATAF) and the OECD have renewed their commitments to promote fair and efficient tax administration in Africa. The cooperation between these organisations amplifies African voices allowing delegates to shed light on the unique challenges and perspectives of the African continent.

The OECD is hosting a virtual event to promote tax certainty. Tax certainty is a priority of the OECD as It promotes investment, jobs and growth. You can sign up for the event until 9 November 2023.

Read our update on key developments in this area since June 2022. HMRC has also made several administrative changes to the Double Taxation Treaty Passport Scheme (“DTTPS”) which is widely used by overseas lenders to ensure UK withholding tax is deducted at the correct rate under the relevant double taxation treaty.  The tax treaties and related documents between the UK and the following countries have been updated:- Czech Republic; Slovak Republic; Cyprus; Chile; Kyrgyzstan; Guernsey; Germany; Luxembourg; India; Isle of Man; Ukraine; and San Marino. Other specific developments of note are set out below:- Use updated form DTTP1 to apply for or renew a Double Taxation Treaty passport; A new UK-Luxembourg Double Tax Treaty was signed in June 2022 and has not yet entered into force; In June 2022, HMRC published a policy paper setting out its change of view on the interpretation of the residence articles in 16 double taxation agreements; Use updated form Canada/Individual to apply for relief at source or claim a repayment of UK Income Tax; Use updated form US-Individual 2002 to apply for relief at source or to claim repayment of UK Income Tax; The UK and Brazil signed a Double Taxation Agreement in November 2022 which has not yet entered into force; and Use updated form DTTP2 to tell HMRC about a 'passported' loan. Changes to the Double Taxation Treaty Passport Scheme (“DTTPS”) HMRC has updated the contact details (both postal and email) for the DTTPS. A number of changes have also been made to the scheme’s terms, conditions and guidance document. HMRC is no longer be reminding passport holders that a passport is due to expire. Previously HMRC guidance  set out that HMRC would write to existing passport holders three months before the passport was due to expire to request completion of a DTTP1 renewal application form. From 20 October 2023 the guidance was updated and now says that HMRC does not issue reminders when a treaty passport is due to expire. The following guidance has therefore been updated accordingly:- Claiming Double Taxation Relief for companies and other concerns; and Double Taxation Treaty Passport Scheme: terms, conditions and guidance.

In this week’s EU exit corner, we bring you the latest guidance updates and publications relevant to EU exit. The latest Trader Support Service bulletin is also available in addition to the most recent Cabinet Office Borders bulletin which has returned from a break. The Minister of State has also written to the Chair of the House of Lords Protocol Sub-Committee providing an update the on the implementation of the Windsor Framework. Miscellaneous updated guidance etc. The following updated guidance, and publications relevant to EU exit are available:- Authorised Consignee Temporary Storage (ACTS) location codes for Data Element 5/23 of the Customs Declaration Service; Remote internal temporary storage facilities codes for Data Element 5/23 of the Customs Declaration Service; Importing bananas you have to pay duty on into the UK; Authorisation type codes for Data Element 3/39 of the Customs Declaration Service; Additional Information (AI) Statement Codes for Data Element 2/2 of the Customs Declaration Service (CDS); Upload documents and get messages for the Customs Declaration Service; Customs Declaration Completion Requirements for The Northern Ireland Protocol; Internal temporary storage facilities (ITSFs) codes for Data Element 5/23 of the Customs Declaration Service; Transit newsletters — HMRC updates; Locations which need a pre-lodged declaration; List of ports using the Goods Vehicle Movement Service; and EM on Windsor Framework customs arrangements.

This week we bring you news about HMRC letters to agents about a potential discrepancy on 2021/22 self-assessment returns, and HMRC has moved the Check Employment Status for Tax tool on to a new platform. The guidance on how remove a taxpayer from the self-assessment regime has been enhanced with two new videos and it is now possible to apply online to join the VAT flat rate scheme. The latest News and Information Bulletin from HMRC is also available which includes a reminder about the planned outages from 6-9 November because of IT upgrades, which we told you about last week. Potential 2021/22 self-assessment discrepancies project We are aware that from early October 2023, HMRC began sending letters to agents about potential discrepancies between their clients 2021/22 self-assessment return when compared to the P11D and P14 forms submitted by employers or child benefit information held by HMRC. The letter does not mention specific clients but advise the agent that HMRC will be in touch within three weeks (unless the agent contacts HMRC first) to share details of the clients where there are potential discrepancies.  According to the letter, if there are any discrepancies, as long as an amendment is made by 31 January 2024, HMRC will not charge a penalty. However, if no voluntary amendment is made by then, HMRC will review and consider making a discovery assessment and charging a penalty. Where an amendment results in an underpayment of tax, interest will apply from the original due date. A late payment penalty may also be payable. HMRC’s aim is to resolve these cases in advance of the 31 January 2024 online filing deadline for 2022/23 self-assessment returns. Check Employment Status for Tax HMRC recently moved its Check Employment Status for Tax (“CEST”) tool to a new platform. The move has not resulted in any changes to the questions asked however users of the tool can now review the answers to their questions after each section. In addition, guidance from HMRC’s employment status manual is now embedded in CEST. Removing a taxpayer from self-assessment HMRC has recently launched two new YouTube videos explaining the online process for taxpayers to stop self-assessment:- How to go online and stop self assessment if you're self employed; and How to go online and stop self assessment if you're not self employed. If a taxpayer believes they no longer need to complete a self-assessment return for 2022/23, it is important that they take action before the 2022/23 online filing deadline of 31 January 2024 in order to avoid being charged a penalty. Apply online to join VAT flat rate scheme HMRC recently launched a new online form which should be used by businesses to apply to join the VAT flat rate scheme (a scheme that simplifies VAT accounting for businesses with an annual turnover of no more than £150,000). Applications can still be made by post.

We recently advised that from mid-November 2023, HMRC will no longer be providing paper VAT1 registration forms on GOV.UK. This will only be available on request from the VAT helpline in exemption cases and certain limited scenarios where online registration is not currently possible. Businesses who are exempt from applying online will still be able to apply by post using a paper VAT1 form. Essentially the exemption from applying online mirrors that available under Making Tax Digital for VAT. HMRC has now confirmed that Monday 13 November 2023 is the date from which VAT registration applications must be made online in the majority of scenarios using the VAT registration service (“VRS”). It has been confirmed that those who cannot apply online are not required to apply for an exemption in advance. However, when calling the VAT helpline, HMRC will ask why a paper VAT registration form is being requested.  It should also be noted that there are several specific types of VAT registration that cannot use the VRS which includes entities (except for UK partnerships or non-established taxable persons) without a unique taxpayer reference. A full list of these is not currently available. Such businesses should call the VAT helpline to request a paper VAT1 registration form. However, HMRC is aiming to add those businesses to the VRS in future, which means that the paper VAT1 form will no longer be available once online registration via the VRS is introduced.   HMRC has also confirmed that should a digitally excluded taxpayer use the services of an agent then the application should be a digital one via the VRS. Work is ongoing to update HMRC’s guidance pages to remove the downloadable VAT1 form, and direct taxpayers to the VRS digital route. This includes letting them know what evidence will be required to be provided in advance of starting an application, including ID verification requirements. At a recent Joint VAT Consultative Committee Meeting, which Chartered Accountants Ireland participates in, external stakeholders asked about the move to more digital routes and if HMRC had tested this with external users, particularly for large organisations with diverse teams over a number of offices. This was particularly raised in the context of submitting online for the first time where it may not be clear what information is going to be needed to start the online form. Forms sometimes disappear after 28 days which can be an issue in larger organisations where it may take longer than this to complete the form. It is also the case that when submitting a form online, all that an employee needs to do is enter the organisation’s email address and tax reference. However, there is no scope to confirm that the submission has been made by the authorised signatory or that the authorised signatory has authorised the submission to be made on their behalf. HMRC’s response to this is set out below. “Prior to HMRC moving to the new VAT Registration Service extensive user research was conducted over a 3-year period with a range of users including agents. The feedback from user research was that the data being requested was reasonable and would be able to be sourced within the timescales provided. HMRC introduced the ability to ‘Save and Return’ an application. This enabling the user the time to gather relevant data if required, without the need to restart their journey again.   The length of time the application remains available is 28 days from the last log in activity, so by using the Save and Return function the length of time to complete the application will extend beyond the 28 days.  On 15 June we updated Register for VAT: How to register for VAT - GOV.UK (www.gov.uk) to include more information on what is required by someone submitting an application for VAT registration. The VRS journey mirrors the VAT1 form and the VAT 1 completion guidance can be used to prepare applications ahead of logging into VRS. VRS asks for the person completing the form to declare the capacity in which they are doing so. Part of the HMRC Charter is that we trust the information being provided to us unless we have good reason not to.   At the point of registration, we will trust that the person submitting the form is an appropriate person to do so, though we do have validation and verification processes in place to inform that decision.   There is no long-standing relationship created by someone applying on behalf of someone else, to do so the appropriate authorisations would need to be completed.”