Start-ups looking to grow have a range of options but carefully considering accounting standards is one way to reduce complexity, write Wuraola Raheem and Paddy McGhee For many Irish high-growth start-ups, the early years are consumed by the cash burn of developing a new product, followed by the cost of growing the market. The nuances of accounting standards are often a secondary consideration.  However, not being aware of some of the accounting standards considerations can have a negative impact on investor confidence and regulatory compliance. Here are nine areas of complexity that often arise for high-growth companies at the start of their journey. IFRS or FRS 102? If an organisation has an international shareholder base and international customers and suppliers, should it use IFRS?  While IFRS is a complete standard recognised globally, its measurement and valuation criteria, together with its disclosure requirements, are burdensome for a small company.  FRS 102 was written with small companies in mind, and in most cases, for a growing company, it will work as well as IFRS.  The decision to move to IFRS will be better taken when the company matures. For example, if a firm acquires other businesses along the way, the requirements for assessing the purchase price allocation are more onerous under IFRS than FRS 102.  Similarly, disclosure requirements are more onerous under IFRS. Revenue recognition There are very few modern businesses for which revenue recognition arises when the invoice is issued. Many companies provide multiple services and warranties, give a right of return or provide a service over a period of time or – increasingly in the tech sector – based on consumption.  This will give rise to the possibility of accrued revenue in which the service is provided in advance of billing or deferred revenue if billing has occurred, but the service or good has not been fully delivered. IFRS, US GAAP and FRS 102 are mainly consistent in their treatment of when revenue is recognised. Many growing companies enter into tailored contracts in order to make those first few sales often giving rise to additional free services or warranties that may lead to revenue deferrals.  Many other firms enter into agreements with large platform companies to sell their products or services, and the lines between marketing and delivery costs and net revenue can become blurred. Accounting for venture capital As companies begin to raise equity, the type of financing used is often not ordinary shares. Common forms of investing include: convertible loan notes; preferential loan notes; preference shares; and shares with a liquidation preference. Today, few investments are in the form of a loan or equity as investors look to protect their investment by having some form of preference. There is often a level of negotiation in these, so funding instruments will almost always have some individual nuances. The impact is that some convertible instruments include a hybrid instrument that needs to be assessed or, in other instances, while something may be called a ‘share’, if it has a fixed return, it may be accounted for as debt. Many companies also overlook the fact that the direct costs of raising equity are recognised in equity, or direct costs relating to debt are capitalised and amortised using an effective interest rate method. It’s not to say that many costs leading up to a finance raise are expensed, such as due diligence fees. Share-based payments There has been much valid criticism in Ireland that share-based remuneration has not received more tax concessions. For a young company, a popular route to attract staff is to offer share options, reducing the cash outlay.  In theory, share options are provided in lieu of a cash salary. Because of this, accounting standards require the intrinsic value of share options at the date they are issued to be recognised as an expense over the service period. Depending on the perceived volatility of the shares and the rights attached to them, this can result in a sizeable non-cash charge to the income statement and one that often does not appear in management accounts. Investing in cloud infrastructure The treatment of expenditure linking a business to cloud-based software has recently been a hot topic for large companies.  The reason for this is that IFRS accounting standard setters recently reminded companies that where they invest in linkages to a cloud-based infrastructure, the related costs should be expensed rather than capitalised on the basis that the firms do not own or control the cloud-based software. This meant that several multi-million Euro enterprise resource planning (ERP) implementation projects were expensed rather than capitalised.  It is easy to see the frustration that some reporters faced as they will receive the benefit of those costs over several years. With many companies reliant on cloud-based infrastructure, it can be a shock to learn that not all the related costs meet the criteria for capitalisation. Capitalised development expenditure “Our enterprise value is €XX million so how come we cannot recognise that value on our balance sheet?” is a common question, followed by: “Given we have spent €XX million on product development, can we capitalise that?” Accounting standards are very detailed on what can be capitalised and what is expensed. Generally, costs relating to internally generated brands, start-up costs, training activities, research, advertising and internally generated goodwill are expensed. The one area in which companies may capitalise costs is where such costs relate to the development of a product or process that can be shown to bring future economic benefit.  There are, however, concise rules on what may be capitalised. While costs can be, it does not mean such costs meet the criteria for claiming research and development (R&D) tax credits.  While the costs can be closely aligned, they are not mutually inclusive. International expansion Given the size of Ireland’s indigenous market, most companies look to international expansion early on. Initially, companies need to assess how they will expand: Do they use foreign subsidiaries to make sales? Is a foreign subsidiary used for providing services to the parent company in sales and marketing, local maintenance or R&D? Regardless of the role played by the foreign subsidiary, from a tax perspective, the share of the taxable profit each country will get will need to be determined. This is where the concept of transfer pricing comes in, and companies need to determine where the profit would reside if the various companies were unrelated. Increasingly with foreign expansion, companies have to deal with employee taxes for foreign employees or employees who move to a new market to help set up a presence. Consolidation requirement As companies grow, they reach a stage where there is a requirement to prepare consolidated statutory financial statements. At a basic level, if a company is defined as a small company under Irish law, it is not required to prepare consolidated accounts. The requirement for consolidated accounts kicks in when a company exceeds two of the following criteria two years in a row: Third-party turnover of €20 million; Gross assets of €10 million; and/or 250 employees. Given the relatively high-level criteria for employee numbers, companies generally meet the requirement when they reach the turnover limit. Other regulatory requirements Irish company law and accounting requirements are generally well legislated for, ensuring that small companies are not overly regulated.  Having reached the consolidation requirement at €20 million turnover, a private company’s next legislative bar is the requirement to have a directors’ compliance statement if it reaches €25 million turnover. Having reached a consolidated turnover of €50 million, a company is required to put an audit committee in place or explain why one is not required. Wuraola Raheem is Audit Manager in Consumer Technology Business at Deloitte Paddy McGhee is Audit Manager in Consumer Technology Business at Deloitte

Chartered Accountant David Malone, Chief Executive of the Irish League of Credit Unions, believes that credit unions are uniquely positioned to fill the gaps left by the departure of major banks and cater to the needs of small businesses and individuals, offering a personalised and community-focused approach Having recently achieved the top ranking in the Ireland RepTrak 2023 study of corporate reputation, credit unions are now poised to provide a real alternative to traditional retail banks for the full range of financial services products.  The credit union sector’s strong local presence with over 500 locations across the island of Ireland demonstrates a clear community focus now combined with soon-to-be-enacted new legislation, which will see credit unions unlock their full potential to become the country’s primary financial services institution of choice. David Malone, Chief Executive of the Irish League of Credit Unions (ILCU), an advocacy body for credit unions in Ireland, believes the unique ethos and DNA of credit unions place them in a strong position to fill the void left by the departure of KBC and Ulster Bank, as well as other service gaps. “There have been significant changes in the financial services sector since the global financial crisis,” he says. “Twelve retail banks were operating in Ireland back then. It’s down to three now. That has led to a lack of customer choice, particularly in the mortgage and SME lending markets, where competition is highly concentrated between the three pillar banks.  “Along with that, we have seen bank branch closures, decimating Irish towns and even where branches remain, decision-making has migrated from the local branch to the centre.” That centralisation has created problems for customers, says Malone.  “For example, small businesses have a real challenge trying to get loans from banks,” he notes. “There is limited interaction with local bank branch managers. Many such loans are turned down. A small business owner can visit their local credit union and sit with staff to explain their business and its needs. Our staff have that vital local knowledge and will understand the specific needs of the business that, in many cases, can help in providing the appropriate loan finance.”  Building relationships Malone joined the ILCU as Head of Finance and Deputy CEO seven years ago, after spending over ten years in audit and assurance with PwC.  “I trained as a Chartered Accountant with PwC after doing my degree in Accounting and Finance and Masters in Accounting at DCU,” he says. “I am now a Fellow of the Institute. It’s a great qualification, providing a real platform for your career. “At PwC, I worked with a wide range of clients, from large Irish plcs to SMEs to Irish subsidiaries of multinationals. Going into different businesses and seeing how they are run was fascinating.” Auditing is much more than a numbers game, he explains. “You have to build relationships with audit clients. You are there to add value and recommend improvements to the client’s financial processes.” He was drawn to the business world as a student during his summer job. “I worked for five summers in my aunt’s business, which was a busy tour operator during the 90s. I learned all about customer service and how the true value of timely and reliable financial information is key to decision-making and strategic direction.” Malone was appointed ILCU CEO in July 2022.  “In conjunction with our board, I had been leading the transformation programme for the organisation prior to that,” he says. “The programme aims to deliver on our new purpose to lead, support and sustain the development of credit unions on the island of Ireland. “Our areas of focus include facilitating collaboration of credit unions, repositioning the credit union brand, and effective advocacy to government and regulators. We also provide a significant suite of professional services to member credit unions in areas such as risk and compliance, legal, human resources and training.” The evolution of credit unions “Our transformation has brought significant additional expertise into the organisation with a number of new skill sets adding huge value as we deliver our purpose,” Malone notes. Malone is excited by the evolution of credit unions. “Credit unions have a 42 percent share of the personal lending market. They have issued close to half a million loans in the last year. In addition, credit unions in over 200 locations across the country are now providing current accounts that are potentially accessible by over two million credit union members. These can be accessed through an app and support Apple Pay and Google Pay. Credit unions now account for over 10 percent of new current accounts opened.” The new legislation, the Credit Union Amendment Bill, is a game changer, Malone says. It allows for the establishment of Credit Union Service Organisations (CUSOs) by groups of credit unions. These CUSOs enable credit unions to pool resources to invest in back-office infrastructure that will enable more credit unions to provide a wider range of financial services, particularly SME lending and mortgages. The new legislation also allow credit unions to provide services to members of other credit unions where the credit unions agree and allows credit unions to pool loans and risk between each other. “Credit unions have significant funds to lend,” says Malone. “They are not relying on the wholesale money markets for their funding. Instead, members continue showing confidence and trust in credit unions by depositing their savings.  “A number of credit unions now offer some of the lowest interest rates in the mortgage market. Credit union mortgage lending has increased by 25 percent in the last year. There is circa €11 billion of funds in credit unions that is available to be lent and can be used to fund small businesses, help people buy their homes, and support community organisations. The new legislation will help credit unions significantly increase their footprint in these areas. “Digitalisation presents great opportunities,” he explains. “Credit unions embrace technology by providing online payments, digital membership and loan applications. However, there is an important difference: credit unions are not digital only; they are digital with the essential human touch. Credit unions are omnichannel, so you can go into a branch or call on the phone and get an answer in real-time.” There is also the issue of financial exclusion. “People still need access to cash, and with banks closing branches and removing ATMs around the country, credit unions have an important role to play in providing that access.” Trusted organisations Malone believes that personal service is the chief reason for credit unions’ top ranking in the Ireland RepTrak 2023 study of corporate reputation.  “We got under the bonnet of that ranking, and we found the key contributors are our human, friendly and authentic service. The study emphasises attributes such as trust and respect, which are core to the ethos of credit unions which are locally owned and managed. We are proud to be at the heart of communities nationwide working towards a more inclusive society, where no one is left behind.” That contrasts sharply with some of the other lenders in the market. Malone is concerned about the impact of ‘buy now pay later’ (BNPL) and personal contract purchase (PCP) products on borrowers. “People don’t realise they are accumulating significant amounts of small debts with these products,” he says. “When people get a loan from the credit union, it’s very transparent and open. We want a lifetime relationship with members. It’s not short-term. Credit unions have helped members consolidate debts to deal with issues created by those products.” He explains that credit union loans are very different to other loans.  “For example, credit union loans provide flexibility, including no early repayment penalties. There is also loan protection insurance that effectively repays the loan in the event of a member’s death. This is a unique credit union benefit that you won’t get with the bank.  “I recently learned about a young person in their twenties whose parents had died. The parents had bank and credit union loans. The credit union loans were paid off automatically as they were covered by the insurance. The bank offered a repayment plan. Our approach is so different to other credit providers. We genuinely care about our members.” That membership is ultimately the critical point of difference, he believes.  “Our members are much more than customers; they are part owners of their credit union. They have a say in how it’s run. Members can volunteer to be on the board and committees. The boards are made up of community volunteers who have the locality’s best interests at heart. They selflessly give their time to credit unions. I would encourage any Chartered Accountant to consider becoming a credit union director, as it is enormously rewarding. “We see credit unions becoming primary financial institutions of choice migrating from the periphery to the front and centre of the financial services landscape,” he continues. “We are building on over sixty years of service to communities around Ireland. We are here to stay, not retrenching or closing – quite the opposite. We are growing and moving forward. We are building on a great reputation and great customer experience. We are offering a much wider range of products and services across the country, and that’s great news for members and the people of Ireland.”

The Pre-Budget Submission 2024 tackles challenges in Ireland, from the ‘green’ transition to inflation and housing supply, offering recommendations to benefit businesses, says Gearóid O’Sullivan Each year, Pre-Budget Submission is prepared under the auspices of the Consultative Committee of Accountancy Bodies – Ireland (CCAB-I).  It is a particularly influential document as it represents not only the views of Chartered Accountants but also our peers in other professional accountancy organisations. The Pre-Budget Submission is overseen by the CCAB-I’s Tax Committee South, of which the membership is predominantly Chartered Accountants. Pre-Budget Submission 2024 This year’s Pre-Budget Submission addresses several key issues impacting business in Ireland, from the so-called ‘green’ transition to the impact of inflationary pressures and, of course, ongoing supply issues on all sides of the residential property market.  The aim of any tax measure is ultimately to support the economy and wider society. Therefore, to the extent a measure represents an initial cost to the Exchequer, the hope and intention is that there is a corresponding benefit that exceeds the cost.  In some instances, the benefit is purely financial, e.g. our recommendation to permanently legislate for the Special Assignee Relief Program (SARP) and, in others, the benefit is a desired change in behaviour, e.g. our recommendation to introduce a ‘Help-to-Insulate’ scheme. Measures to alleviate capacity issues in the residential property market The residential property market faces issues on both the rental and retail sides.  On the rental side, we continue to advocate for measures to make renting more attractive, particularly for small-scale and accidental landlords.  Despite tax legislation recognising taxable profits in many cases, often small-scale and accidental landlords find themselves in a cash-flow negative position when the tax bill and any loans on the property are taken into account.  While it is reasonable to mention the economic benefit achieved through property ownership over the longer term, the cash-flow impact is often driving these small-scale and accidental landlords out of the rental market.  If this cohort of landlords were, in turn, selling their investment properties, there could be a sound basis from a policy perspective in maintaining the rules in their current iteration.  However, landlords will often have to first seek to evict and then sell. As such, vacancy represents a key policy issue for government when designing appropriate taxation rules for landlords. With the above in mind, CCAB-I has made several recommendations that we suggest will make letting sufficiently attractive for smaller-scale and accidental landlords: Local property tax should be available as a deduction against rental income. Expenses deductible under section 97 TCA 1997 should be aligned with Case I/II principles. Expenses that are revenue in nature and incurred wholly and exclusively for the purpose of the rental business should be deductible, and rental losses should be available for offset against other income. Capital allowance rates for fixtures and fittings should be increased from 12.5 percent to 25 percent per annum to facilitate landlords investing in the maintenance of properties, providing the works do not result in the termination of an existing tenancy. Landlords who retrofit a property to enhance the property’s energy rating should be able to claim a 100 percent capital allowance where the renovations do not result in the termination of an existing tenancy. The Government should introduce measures to bring parity to the taxation of corporate and individual professional landlords by introducing a flat rate of 25 percent on Case V income for small landlords who opted to become ‘professional landlords’ by waiving their rights under Section 34 of the Residential Tenancy Act (2014), giving additional security to their tenants. We have also suggested a reasonable capital gains tax (CGT) relief to incentivise property sales with tenants in-situ: Professional landlords should be given access to succession reliefs (e.g. CGT retirement relief) to improve the long-term investment proposition of the residential rental business. To encourage landlords to remain in the private rental market, CGT relief of four percent per annum should accrue for the length of time the asset remains a rental property. (This was specifically examined in a 2017 Report of the Working Group on the Tax and Fiscal Treatment of Rental Accommodation Providers.) In addition to the above, we are also recommending that Government increases ‘Rent-a-Room’ relief to match standardised average rents and to remove the ‘cliff-edge’ over which relief is completely removed. Measures to combat inflationary pressures The level of inflation in the Irish economy is putting significant pressure on households.  The European Central Bank began increasing interest rates in a bid to dampen inflation. There is a balance to be struck between tax measures to combat inflation and the policy aim of reducing spending capacity. With that said, there is scope for a reasonable change in the personal tax regime, which should not be incongruent with the policy objectives of the European Central Bank.  Earlier this year, CCAB-I responded to the Department of Finance’s consultation on Ireland’s personal tax system. The Pre-Budget Submission includes many of the points raised in that earlier submission, including a recommendation to move to indexation of the income tax bands and credits.  In Ireland, a taxpayer begins to pay tax at the higher rate from €40,000, although the average industrial wage is €46,800. Therefore, the application of an indexed approach to increasing bands and credits should ensure that tax bands and credits remain valuable year to year. Otherwise, while the Government may not raise bands and credits in a particular year, the real value of after-tax wage is likely to have decreased due to the impact of inflation. We also recommend changes to other areas of the personal tax system, including several changes to the CGT and capital acquisition tax (CAT) regimes. These include: The CGT annual exempt amount available under section 601 TCA 1997 should be increased to €5,000.  The CGT indexation tables in section 556 TCA 1997 should be extended beyond 2003 to the present day. The rates of CGT and CAT should be reduced to 20 percent. The lifetime limit for claiming revised entrepreneur relief under section 597AA TCA 1997 should be increased to €5 million. The category A threshold for CAT should be increased to €350,000 in line with a rate reduction. The CAT small gift exemption should be increased to €5,000. Employers’ PRSI should not be increased at this time. As in 2022, we are also recommending that further consideration is given to an intermediate rate of income tax. This is a longer-term ambition.  However, the current system is complicated by the fact that we have three separate taxes on personal income (income tax, USC and PRSI). As such, all these taxes could be redesigned into a single tax, and in this scenario, an intermediate rate of tax becomes a key tool. Further recommendations Pre-Budget Submission includes further recommendations on measures to assist climate change, support foreign direct investment, SMEs and entrepreneurs, and enhance the tax system generally.  The document is a key feature of the tax department’s annual output. It reflects the views of professional accountants across the country and is presented directly to the Department of Finance each year.  While the Government faces several challenges in this year’s Budget as it balances a substantial surplus with increasing societal needs, it is hoped that our recommendations will be considered in terms of the benefit we believe they will bring to businesses in Ireland. Gearóid O’Sullivan is a Tax Manager at Chartered Accountants Ireland 

Imelda Hurley, CEO at Coillte, the semi-state forestry company, talks about her passion for sustainability and the importance of Ireland’s climate action and biodiversity agenda for the Irish economy and society  Imelda Hurley knew from an early age that she was destined for a career in business. Hurley tells Accountancy Ireland about her career path and how Coillte’s strategic vision will further support its contribution to Ireland’s climate targets, optimising the multiple benefits from forestry.  Tell us about yourself and the start of your career. I grew up on a family dairy farm just outside Clonakilty in West Cork. My first job was with Clonakilty Black Pudding, a little-known brand back then, but now a very successful and entrepreneurial operation. I completed a Business Studies degree at the University of Limerick. Following that I joined Arthur Andersen and became a Chartered Accountant. During that time, I had the opportunity to engage with multinationals and indigenous companies. That gave me a great lens into how organisations successfully operate, develop and implement strategy. How has your career evolved since you qualified as a Chartered Accountant? A: I always had an ambition to become a CFO and eventually a CEO. My career experience has been from farm to fork to forestry, working in the food, agribusiness and agriservices businesses across a variety of ownership structures.  During my role as CFO and Head of Corporate Sustainability at PCH International in China, I had the opportunity to learn more about sustainable product development and supply chain management.  That was over 10 years ago, when few organisations were talking about sustainability. I’m left reflecting on how times have changed over those 10 years and how there is an increased focus on sustainability today.  You were appointed as CEO of Coillte in November 2019. Tell us about your role and what attracted you to the position. I really enjoy the outdoors and nature. Coillte gave me a great opportunity to work in a business with a commercial focus, but also a business delivering social good. I joined Coillte in November 2019 and I spent much of the first two years navigating the pandemic. I wanted to ensure that Coillte emerged from the pandemic as a sustainable, viable and vibrant organisation. I am pleased to say that when we reported our 2021 results, we delivered record revenues, record profitability and a record dividend to the State.  Coillte manages 440,000 hectares of primarily forested land, circa seven percent of Ireland’s land, with about 6,000 individual properties. We have just over 800 employees and 1,200 contractors working across three divisions: Coillte Forest, Land Solutions and Medite Smartply.  Coillte is the nation’s largest forester and producer of certified wood, a natural, renewable and sustainable resource and the largest provider of outdoor recreation space in Ireland. It enables wind-energy on the estate, processes forestry by-products and undertakes nature rehabilitation projects of scale. When you were presented with your Businessperson of the Year Award in December, you were described as an “advocate for sustainable business practices and a leader in sustainability discussions”. Why is sustainability important to you? We are on a journey that requires us to leave the planet in a better place than we found it. There is a financial balance sheet but also an environmental and social balance sheet. Good business brings these together. From my perspective, I accepted the award on behalf of Team Coillte, all of whom work every day to balance and deliver the multiple benefits of forestry.  Tell us about the strategic vision you launched last year and Coillte’s plans for the next 12 months and beyond. In April 2022, we launched a new forest strategic vision focusing on four pillars – Forests for Climate, Wood, Nature and People. This vision sees us, as an example, enabling the creation of 100,000 hectares of new forests by 2050. Those forests will sink approximately 18 million tonnes of CO2.  We are also working on how we manage our existing forests to capture an additional 10 million tonnes of CO2 by 2050.  We have an ambition to redesign approximately 30,000 hectares of peatland forests through a programme of rewetting or rewilding for climate and ecological benefits and also aiming to enable the generation of one gigawatt of renewable wind energy by 2030.  From a people and recreational perspective, we are targeting to enable €100 million of investment to create world-class visitor destinations by 2030.  In July 2022, we launched Beyond The Trees, Avondale at Avondale Forest Park in County Wicklow and in June of this year, we opened the newly refurbished Avondale House, further adding to Avondale Forest Park experience, which has had over 300,000 visitors since June 2022. Our ongoing focus is to continue to ensure a strong, viable, vibrant Coillte that focuses on optimising our contribution to Ireland’s Climate Action plan, while continuing to deliver sustainably certified timber to support the decarbonisation of the built environment.  Our strategic vision also involves increasing from 20 percent of the estate being primarily managed for nature and biodiversity to 30 percent by 2025 and to 50 percent in the long-term. Another major focus for us is workforce capacity, planning for our organisation and the industry more broadly. We have 440,000 hectares under management and between now and 2050 the State has an ambition to increase forest cover from 11.6 percent to 18 percent. As such there will be a requirement to attract more people into our sector going forward. Are you glad you made the decision to qualify as a Chartered Accountant and what career advice would you offer your younger self? A: In the early years of my career, I looked up to others. Ultimately, I realised what was much more important was to follow my own path and enjoy the journey. You have to do what makes you happy and if you work hard and are determined, good things will come.  

The European Commission (EC) has adopted the European Sustainability Reporting Standards (ESRS) on 31 July 2023. This marks a significant milestone in the development of European Sustainability Reporting Standards and is the culmination of great effort from the various parties tasked with its development- including the EFRAG Sustainability Reporting Board, the EFRAG Sustainability Technical Expert Group, its initial Project Task Force and respondents to the recent consultations on the ESRS. The EC has also published a press announcement and Q&As and have indicated that additional implementation guidance will be prepared and made available over the coming months. The standard will enter into force following its publication in the Official Journal of the European Union and the first wave of entities will report under the ESRS for periods commencing on or after 1 January 2024. The reporting requirements will then be phased-in over the subsequent years to various company types and sizes. If you wish to find out more about the ESRS, please see our recent free webinar "Further your knowledge about the European Sustainability Reporting Standards"

The International Accounting Standards Board (IASB) has announced that it has concluded its decision making on two projects and will begin drafting and balloting two new IFRS Accounting Standards. The IASB expect to issue the new standards in the first half of 2024. The first of these standards will be the result of the Primary Financial Statements project and will supersede IAS 1 Presentation of Financial Statements. This standard will result in companies reporting more consistently and transparently on their financial performance, making it easier for investors to compare companies. The second standard is the result of the Subsidiaries without Public Accountability: Disclosure project and will reduce the disclosure requirements for subsidiaries that are not traded on a public market, or who do not hold assets entrusted to them by their customers. The IASB have decided that the effective date for the two new standards will be periods commencing on or after 1 January 2027, with early adoption permitted.

The Financial Reporting Council (FRC) has published a thematic review entitled “CRR Thematic review of climate-related metrics and targets” which assesses the quality and maturity of climate-related metrics and targets disclosures across 20 companies annual reports for 2022. The review focusses on 4 sectors- materials and buildings, energy, banks and asset managers. The report is intended to assist preparers in the preparation of climate-related disclosures and highlights instances of good practice identified as well as opportunities for improvement and omissions identified. Throughout the report the FRC consider the following overarching questions; Has companies’ climate-related metrics and targets reporting improved since last year? Are companies adequately disclosing their plans for transition to a lower carbon economy, including interim milestones and progress? Are companies using consistent and comparable metrics? Are companies explaining how their targets have affected the financial statements? Overall, the report shows an improvement in the quality of companies’ disclosures of net-zero commitments and interim emissions targets, however it also noted that disclosures of actions and milestones required to meet these targets were sometimes unclear.  

The International Auditing and Assurance Standards Board (IAASB) has announced that it plans to issue its proposed sustainability assurance standard, International Standard on Sustainability Assurance 5000 (ISSA 5000) on 2 August. This will then be subject to public consultation until early December to allow for stakeholder feedback. In making the announcement the IAASB stated that "When approved, ISSA 5000 will be the most comprehensive sustainability assurance standard available to all assurance practitioners across the globe. It will apply to sustainability information reported about any appropriate sustainability matter and prepared under any suitable framework. It will also apply for both limited and reasonable assurance engagements."

Seeking a new adventure, Ailish Byrne's ACA qualification brought her to Bermuda.  Where did you grow up and where do you live now? I grew up in Kilcoole in Co. Wicklow (of Glenroe fame!) and moved to Bermuda in April 2022 to work as Chief Compliance Officer with the Bermuda Stock Exchange (BSX). I spent all my career in Dublin except for a year in Australia post qualification. What made you choose to become a Chartered Accountant? I was always interested in business subjects in school, particularly accountancy. I liked languages too and thought I’d like to combine the two and initially chose to do Languages and Marketing (German and Spanish) in Dublin City University (DCU). However, I realised fairly quickly that the course was too language focused for me. After completing first year, I switched into DCU’s Accounting and Finance where I was much happier. After that, becoming a Chartered Accountant was highly likely as a career path once you secured a training contract. Can you tell us a little about how you got to where you are today – both the geographical relocation and career path? I was looking for a new role post Covid and I wasn’t attracted to the job opportunities in Ireland. I decided an adventure abroad might be fun. Turns out the BSX was looking to replace their Chief Compliance Officer who was retiring. I had worked in the Irish Stock Exchange (ISE) for 18 years in two different roles – as Head of Regulation and Head of Communications and my exchange experience was a perfect fit for what they needed. It was great timing! What do you value most about your membership of the profession and how do you think those benefits can be used to support the economy and society? Being an Irish Chartered Accountant has given me career opportunities and experiences that I would not have had without my qualification. Accountancy training gives you a mindset and a way of thinking that can be applied to lots of different roles and challenges. I’ve taken a non-financial accounting path and worked in internal audit, communications, compliance and regulatory roles - who knows what’s next! How has your membership been of value to you globally and what do you value about it now that you’re living overseas (and what would you like to see more of)? The Irish Chartered Accountancy profession is a ready-made network of people.  When I contacted Gillian Duffy, the Global Member Manager, about a potential Bermuda Chapter she said there was about 90 members living in Bermuda. We had our first event in May and for our July event, Chartered Accountants Ireland President, Sinead Donovan, was visiting so the timing was brilliant. I think the Chapters are a great way to keep ties with home and meet other members of all ages when you are working overseas. What were the most significant differences you encountered doing business and networking in a completely new location a long way from home? Bermuda has a culture all its own – it has a blend of British, Caribbean, Portuguese and American influences. It’s true that Bermuda shorts are considered business attire during the summer months! Business is more relaxed though it can be more formal and bureaucratic too. With a population of less than 60,000, I find everyone really does know everyone and people are friendly so it makes networking fairly easy as long as you are happy to get involved and join in.  

The FRC Lab has published a report entitled "ESG data distribution and consumption- Optimising the flow of ESG data from companies to investors". This report is the second phase of the FRC Lab's ESG data project, having published "Improving ESG data production" in 2022. This report examines how investors access and collect ESG data and how they use it. Specifically, it looks at the following three elements of relevance to ESG data; Motivation- What motivates investors to collect ESG data? Method- How do investors collect the data? Meaning- How do investors integrate ESG data into their investment processes?

This week we bring you news of new guidance and a form for anyone self-employed and working abroad. HMRC has also asked us to publish “Handy hints for taxpayers – June 2023”. Read HMRC’s update on new employees, and we remind you that from next month the research and development (“R&D”) Additional Information Requirements form must be submitted with all R&D tax relief claims, although this commences from the later date of 8 August 2023. The latest report from the Department for Trade on the National Minimum Wage is also available, and HMRC has published updated guidance on “How HMRC advice and information can help you”. New guidance and form for self-employed taxpayers working abroad New guidance and a g-form are available for any self-employed individuals who are working abroad and wish to apply for a certificate to confirm they pay UK national insurance. The form should be used to ask HMRC to confirm that you only need to pay UK social security contributions if you are a self-employed individual working temporarily in an EU country, or Gibraltar, Iceland, Liechtenstein, Norway, or Switzerland. HMRC’s update on new employees HMRC has sent an email about upcoming activity to support employers with new starters. The email sets out useful tips to help employers get their staff on the right starter declaration and tax codes.  R&D Additional Information Requirements form commences from 8 August 2023 From 8 August 2023, a week later than the original commencement date of 1 August 2023, companies must complete and submit the Additional Information Requirements (“AIR”) form to HMRC to support all claims for R&D tax relief or the R&D expenditure credit. The AIR form must be sent before submitting the company’s Corporation Tax Return which includes the R&D claim. Failure to do so means that HMRC will write to the company to confirm it has removed the claim for R&D tax relief from the Corporation Tax Return. According to HMRC, the delayed commencement date is designed to give companies more time to prepare. The Relief for Research and Development (Content of Claim Notifications, Additional Information Requirements and Miscellaneous Amendments) Regulations 2023 were published last week and codify the content of both the AIR form, and the Claim Notification form, which are both mandatory requirements for R&D tax relief claims to be considered valid. Chartered Accountants Ireland is represented on HMRC’s R&D sub-group forum and would welcome any feedback or questions on either the AIR form or the Claim Notification form. Department for Trade’s annual National Minimum Wage report The Department for Trade’s annual National Minimum Wage report was published last month and named over 200 employers for failing to pay their staff the National Minimum Wage. Guidance for employers on pay continues to be available on GOV.UK. Additional advice has also been published about breaches and the steps employers should take to make sure they pay their workers correctly. Updated guidance “How HMRC advice and information can help you” HMRC has published updated guidance “How HMRC advice and information can help you”. Some of the key changes made are as follows:- It should be clearer what types of information, or advice the statement applies to; Links are included to the HMRC Charter, and a link to the Admin Law Manual which covers “Legitimate Expectation” (“LE”) in more detail; and It is now clearer that HMRC can consider applying the correct tax position prospectively, something it always did as part of LE but did not say in the guidance.  The updated statement is based on stakeholder feedback from the Guidance Strategy Forum, with further improvements expected to both the guidance, and the Admin Law Manual.  HMRC are keen to hear feedback on the changes and is also considering more opportunities to signpost to the guidance.  

Last Tuesday 18 July was “Legislation Day” (or “L-day”) when the Government published draft legislation for inclusion in Finance Bill 2024. Also published were explanatory notes, tax information and impact notes, responses to consultations, several new consultations, and other supporting documents. L-Day came just days after the Spring Finance Bill 2023 received Royal Assent to become the Finance (No. 2) Act 2023, and the second Finance Act of 2023. Following the Spring Finance Bill 2023 receiving Royal Assent, the Government published a statutory instrument implementing the new UK transfer pricing (“TP”) documentation requirements. The Transfer Pricing Records Regulations 2023 mean that for the first time the UK has mandatory TP documentation requirements. HMRC have also published new guidance on this in its International Manual. Chartered Accountants Ireland is disappointed to see draft legislation published last week on L-day for the potential merger of the UK’s SME and large company R&D schemes from April 2024 which we were opposed to in our response to this consultation earlier in 2023. However, we are pleased to see that the Government plans to simplify how the high-income child benefit charge is collected which was a recent recommendation in a consultation response in June. Last week’s L-day announcements contained few surprises and largely built on previous policy announcements at both Spring Budget 2023 and April’s Tax and Administration Maintenance Day. The Government also made some announcements in a small number of technical tax policy areas and published some new consultations and summaries of responses to previous consultations. Changes to the UK’s Pillar Two rules also featured which we will cover in detail next week. The Government also intends to change the income tax rules for anyone who inherits a pension which will make them liable for income tax at their marginal rate from 6 April 2024. This announcement was made briefly in the guidance on abolishing the pensions lifetime allowance which was published on L-day last week. Other headlines from last week’s L-day announcements included:- Research and development tax reliefs – draft legislation to introduce a new permanent rate of relief for the most R&D intensive loss-making SMEs from 1 April 2023 and on the proposed design of a potential merged scheme combining the SME and RDEC schemes. Further, the restrictions on overseas R&D expenditure, delayed from April 2023, will be introduced for expenditure incurred on or after 1 April 2024. With a few exceptions, expenditure on overseas R&D will no longer be qualifying; Reform of audio-visual creative tax reliefs – draft legislation to implement the previously announced modernisation and reform of the existing audio-visual tax reliefs into expenditure credits. The reforms include a higher rate of relief for animation and children’s TV, which will also be extended to animated films; Administrative changes to the high-income child benefit charge – the Government wants to simplify the process for those who become liable to this, particularly for those who currently need to register for Self-Assessment (“SA”) to pay the charge. Details will be provided in due course on how this will enable employed taxpayers to pay this through their tax code, without the need to register for SA; and Data HMRC collects from taxpayers – the draft Finance Bill clauses have been published for technical consultation before introducing the changes in the Autumn Finance Bill. Subsequent amendments to regulations will be required to enact the changes and set out the detailed requirements. The changes will take effect from no earlier than 2025/26 and broadly the changes mean that HMRC will be given extra powers to collect information about the amount of dividend payments earned by owner managed business directors while employers will have to report the number of hours worked by individual employees. HMRC will continue working closely with businesses and other affected parties to progress these changes, ensuring clear requirements, guidance, and adequate time for implementation. If you have any comments or questions about the draft legislation, please email: responsivenessdataconsultation@hmrc.gov.uk In addition, the following consultations have been published: Mass Balance approach to account for chemically recycled plastic for Plastic Packaging Tax; Tax incentives for occupational health; Taxation of Employee Ownership Trusts and Employee Benefit Trusts; and Review of the VAT Terminal Markets Order legislation.

The second 2022/23 self-assessment payment on account for income tax and Class 4 NIC (National Insurance Contributions) is due for payment on or before midnight Monday 31 July 2023. Each payment on account is half of the previous year’s tax bill. Information on time to pay arrangements and how to apply is available on GOV.UK. Anyone who is self-employed is required to make two payments on account every tax year unless:- their last Self-Assessment tax bill was less than £1,000; or they’ve already paid more than 80 percent of all the tax owed, for example through their tax code. If a taxpayer knows their tax bill is going to be lower than last year, a request can be made to HMRC to reduce payments on account.

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. We also remind you that the deadline for applying for the new UK Internal Market Scheme to ensure applications are processed in time is next Monday, 31 July. Miscellaneous updated guidance etc. The latest documents and publications relevant to EU exit are as follows:- Reference Document for The Customs (Northern Ireland) (EU Exit) Regulations 2020; Report payments and view your allowance for non-customs state aid and Customs Duty waiver claims; Check if you can claim a waiver for goods brought into Northern Ireland; Request Customs Declaration Service data on imports and exports; 4-digit to 3-digit procedure to additional procedure code correlation matrix for imports; Simplified procedures exclusion list of procedure and additional procedure codes for CDS; Appendix 2: DE 1/11: Additional Procedure Codes of the Customs Declaration Service (CDS); Reading notes for Declaration Category Data Sets: CDS Declaration and Customs Clearance Request Instructions; Additions and deductions for Data Element 4/9 of the Customs Declaration Service; Appendix 1: DE 1/10: Requested and Previous Procedure Codes of the Customs Declaration Service (CDS); CDS Declaration Completion Instructions for Imports; Appendix 21: Import Declaration Category Data Sets; Imports and Exports of the Customs Declaration Service (CDS); Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service; Authorised Consignee Temporary Storage (ACTS) location codes for Data Element 5/23 of the Customs Declaration Service; Maritime ports and wharves location codes for Data Element 5/23 of the Customs Declaration Service; Notices made under the Customs (Export) (EU Exit) Regulations 2019; Bringing commercial goods into Great Britain in your baggage; and Notices made under the Customs (Import Duty) (EU Exit) Regulations 2018.

HMRC’s latest schedule of live and recorded webinars is now available for booking. Spaces are limited, so take a look now and save your place. Basis period reform – moving to the tax year basis: book now This webinar provides an introduction to basis period reform and looks at:- The tax year basis applicable from 2024/25 The transitional year to basis period reform of 2023/24; and Overlap relief. Agent services account access groups: book now This webinar looks at access groups within the agent services account including:- about access groups; clients lists and transacting with clients; adding team members; managing access groups; examples; and error messages, filters, and client references. An overview of the new alcohol duty structure and rates: book now From 1‌‌‌ August‌‌‌ 2023, alcohol duty will be charged in relation to the strength of the product as opposed to the product type. This webinar will explain the new alcohol structure and rates, including the reduced rates for draught products An overview of the new alcohol duty structure and small producer relief: book now This webinar will provide a background into the new small producer relief, including eligibility criteria, and how to calculate this. Capital allowances and vehicles: book now This webinar is part of HMRC’s annual Self-Assessment programme covering the rules for cars, qualifying expenditure, pools and rates, and vehicle hire purchase. A recording is also available to register to view of the webinar UK freeports – examples of tax and customs benefit.

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.

The OECD will publish its annual review of Asia and the Pacific tomorrow. The publication, “Revenue Statistics in Asia and the Pacific”, presents key indicators tracking progress on the mobilisation of domestic resources and informing tax policies to bridge the financing gap for the Sustainable Development Goals to build sustainable public finances in the wake of the pandemic.

 Employee well-being is vital for business success. Moira Grassick explores the biggest people risks, from stress to diversity, and outlines how you can strengthen your organisation’s resilience A business is only as successful as its employees. People are both the most important asset a business has and, on the other hand, a source of risk if they’re not properly managed. After a stressful number of years in which health and well-being were primary concerns for everyone, the workplace has changed irreversibly, and it’s up to business owners to adapt to ensure their people stay happy and, in turn, deliver business growth. Some business risks are outside the control of Irish employers. Global geopolitical tensions and interest rates continue to impact the cost of doing business, but it’s different when it comes to your people. Employee risks are within your control. Here are some risks your organisation can minimise, ensuring happier and more productive employees. Stress and burnout After a challenging number of years, your employees may be suffering from anxiety, stress or burnout symptoms. These psychosocial issues can have a direct impact on productivity and potentially on the reputation of your business. Employees are more focused than ever on work-life balance and well-being. Taking steps to help employees achieve their goals in these areas helps reduce errors, minimise staff turnover and avoid dips in productivity. Remote Health & Safety  A remote worker’s home workstation is an extension of the workplace, and employers need to consider their Health & Safety obligations in this regard. The main responsibility for Health & Safety at work rests with the employer regardless of whether an employee works remotely or onsite. A risk assessment of the employee’s home workspace should be carried out. Work-related injuries (both physical and psychosocial), whether they happen onsite or in a remote location, could lead to penalties, brand damage and a deterioration in employee relations. Recruitment and retention Although the labour market shows signs of turning back in favour of employers, it’s crucial for business owners to figure out what will help staff build long-term careers with them. High staff turnover is bad for business, so engaging with employees and responding to their feedback on what could help them build a long-term future with you will pay dividends. Workplace culture Serious misconduct like bullying and harassment or theft and fraud can derail a business. It’s vital to manage these risks through the effective operation of appropriate policies and procedures. Staff should be aware of the values they are expected to uphold. Likewise, if employers don’t deal with grievances in the correct manner, they risk demoralising staff who won’t want to work within an uncaring culture. Preventing grievances in the first place should be the aim, but failing to manage employee grievances properly will distract your management team from their main tasks, demotivate staff who think colleagues have not received fair treatment and ultimately hurt your business. Diversity, equity and inclusion As the Irish population continues to diversify, it’s important to develop an inclusive and diverse working environment. Failing to address this area will limit your access to the broadest possible talent pool and potentially have reputational consequences that hurt relationships with employees, customers and other stakeholders. Legal and compliance As well as the challenge of managing the transition away from pandemic-related work practices, employers also have a wide range of new employment laws to consider. The statutory sick pay scheme came into force in January and affects all employers. The transparent and predictable working conditions regulations impact probation periods, employment contracts and documentation. Most recently, employers will need to act upon various new work-life balance rights, including the right to request remote work. It’s a major challenge for employers and employment law practitioners to keep pace with the volume of recent employment regulations. The cost of ineffective management The costs associated with these risks are multiple. Management spends too much time firefighting, employees take their talents elsewhere, and the bottom line suffers. With the right approach, however, business owners can turn all these risks into strengths that will make their business more resilient to setbacks and more productive when trade is brisk. Moira Grassick is Chief Operating Officer at Peninsula Ireland

In the modern business landscape, fostering a culture of accountability is paramount for organisational success and ethical behaviour. Yvonne Kelleher and Conor McCarthy discuss the crucial connection between culture and accountability Culture and accountability are not new concepts. However, for many organisations, driving a culture of accountability seems like an intangible feat, with many organisations leaping to enhance the operating model without recognising the need to manage the human factors. This can be a costly oversight, and without considering a unified approach and mindset to drive accountability, the desired benefit and return will not be realised. Executives must set a leading example in this time of increased public and regulatory scrutiny and change in Ireland and globally. They need to exhibit accountability and maintain trust with both stakeholders and employees. Culture and accountability are not static ideas, nor do they impact one industry. In fact, in Ireland, we have seen over the last 12 months a lack of accountability underpinned by poor behavioural drivers across a range of industries such as financial services, public bodies and broadcasting has resulted in computational damage and a loss of stakeholder and employee trust. Time is of the essence for organisations to conduct a stocktake, reassess their culture journey and address any gaps to promote and embed an effective and resilient culture to drive and enforce accountability. Organisations should look at this as not only a necessity but also an opportunity that will support their success in the long run.  Organisational accountability – what is it? Organisational accountability occurs when all employees behave in a way that promotes the successful and timely completion of their responsibilities. It involves the organisation being answerable for its actions, decisions and impact on stakeholders, including employees, customers, shareholders, communities and, of course, the environment. A poor culture of accountability can present itself in several ways. Lack of transparency There is often a lack of transparency in decision-making processes, communication and reporting. Information may also be withheld, buried, distorted or not shared openly with stakeholders.  Lack of clarity in roles and responsibilities When there is a lack of clarity regarding roles, responsibilities and expectations, it becomes challenging to establish accountability. Unclear lines of authority, ambiguous decision-making processes, and overlapping responsibilities can contribute to a culture where no one feels truly responsible or accountable for outcomes. Lack of leadership Leadership plays a crucial role in shaping the culture of an organisation. In a poor culture of accountability, leaders may fail to model and uphold the principles of accountability. Leaders evading responsibility or engaging in unethical behaviour without facing the consequences sets a negative example for others.  Lack of trust There may be an environment of distrust and scepticism. This can lead to a lack of collaboration, communication and willingness to report issues and mistakes.  Low consequences for misconduct In organisations with a poor culture of accountability, there may be a lack of appropriate consequences for unethical behaviour or poor performance. This can lead individuals to believe they can engage in misconduct without facing significant repercussions.  Fear of retaliation Conversely, a poor culture of accountability may foster an environment where individuals fear retaliation for speaking up, reporting wrongdoing or challenging the status quo. This fear can deter individuals from holding themselves or others accountable, leading to a lack of transparency and the perpetuation of negative behaviours. It is crucial, therefore, to get a balance between consequences and a fear of retaliation.  Low morale A lack of organisational accountability can diminish an employee’s sense of purpose. This results in a lack of motivation to do your job and impacts the quality of employees’ work.  The link between culture and accountability Today, an organisation’s success is no longer just about the bottom line; qualitative inputs like transparency, trust and employee performance, productivity, collaboration and engagement also determine success. Therefore, an organisation’s cultural norms, values and practices can significantly influence the expected, accepted and enforced accountability level to ensure sustainable change. 1. Trust and transparency   Culture affects the level of trust and transparency within an organisation. In cultures where trust is high, and transparency is valued, accountability tends to be emphasised more. Employees tend to hold themselves accountable for their actions as they believe in the importance of integrity and honesty.  2. Consequences and enforcement Cultural attitudes towards consequences and enforcement also play a role in accountability. In some cultures, the fear of reputation, trial by the media or social stigma may serve as a powerful deterrent leading individuals to be more accountable for their actions. In other cultures, legal frameworks and regulatory systems play a key role in enforcing accountability (like the new individual accountability regime currently being implemented by the Central Bank in regulated institutions within Ireland).  Cultural influences Cultural influences on accountability can vary significantly across different societies and organisations, particularly as the operating and workforce landscape evolves. While some cultures may prioritise individual accountability, others may emphasise collective responsibility more. Understanding and addressing these cultural dynamics, including behavioural drivers, are essential for promoting a sustainable culture of accountability and ethical behaviour. Yvonne Kelleher is Managing Director in Risk Consulting at KPMG Conor McCarthy is Partner, Head of People and Change at KPMG