The FISC Subcommittee on Tax Matters will hold a public hearing on the tax implications of the Trump administration’s policies next week on Tuesday 23 September 2025. The hearing is an opportunity to both consider the evolving dynamics of EU-U.S. tax relations and to reflect on how the EU can safeguard its interests in a rapidly changing global context.

The OECD has published its annual report on Tax Policy Reforms for 2025. The report covers the tax policy reforms introduced or announced in 2024 in 86 member jurisdictions of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), which includes all OECD countries.

Revenue has restructured its guidance on Capital Acquisitions Tax (CAT) and has published two new manuals, the CAT Administration Manual and the CAT Manual which replace the existing guidance. Apart from minor changes, the contents in both manuals have been taken directly from pre-existing guidance. Revenue has confirmed that links to the documents in the manuals will be updated over the coming weeks and a table has been provided which lists the titles of the documents in the new CAT manual and indicates the source of the guidance contained in each document. The new CAT Administration Manual contains the following details: CAT Part 01 - Introduction to Capital Acquisitions Tax CAT Part 02 - Statement of Affairs (Probate) Form SA.2 CAT Part 03 - The Self-Assessment Tax Return (Form IT38) CAT Part 04 - Certificates of Discharge Guide to Capital Acquisitions Tax Compliance Intervention The new CAT Manual covers the following topics: Part 02 - Gift Tax Part 03 - Inheritance Tax Part 04 - Value of Property for Tax Part 05 - Provisions relating to Gifts and Inheritances Part 06 - Returns and Assessments Part 07 - Payment and Recovery of Tax, Interest and Penalties Part 09 - Exemptions Part 10 - Reliefs Schedules

Revenue has published the Karshan Disclosure Opportunity Guidance, outlining detailed information regarding possible settlement arrangements arising from the Supreme Court’s decision in Revenue Commissioners v Karshan (Midlands) Ltd. This follows the publication in May 2024 of the Revenue Guidelines for Determining Employment Status for Tax Purposes, which was update to reflect the decision in Karshan. In a recent press release, Revenue notes that “the judgment changed the understanding of the correct legal principles and legal tests to apply in determining whether an employer had correctly classified workers as employees or as self-employed”. Where a business or employer deems that it is necessary to make a disclosure and that disclosure can be treated under the new guidance, the disclosure must be made no later than Friday, 30 January 2026. In the new guidance note, Revenue states the following: “Revenue invites employers impacted by the Supreme Court ruling to make a disclosure in respect of 2024 and 2025. Revenue will treat any adjustment of liability in respect of both years as a “technical adjustment” as provided for in the Code of Practice for Revenue Compliance Interventions. This means that Revenue will not consider liabilities to have arisen from either deliberate or careless behaviour and a tax-geared penalty shall not apply to any liabilities to Income Tax, USC and PRSI in respect of these years. In addition, fixed penalties will not apply.” At the time that the judgment was released, the Institute engaged extensively with Revenue through the Tax Administration Liaison Committee. You can find links to the various meetings where this issue was discussed below: Minutes of TALC Direct and Capital Taxes Sub-Committee - 30 November 2023 Minutes of TALC Direct and Capital Taxes Sub-Committee - 29 February 2024 Minutes of TALC Direct and Capital Taxes Sub-Committee - 25 April 2024 Minutes of TALC Direct and Capital Taxes Sub-Committee Meeting - 12 June 2024 Minutes of Main TALC Meeting - 27 June 2024 As part of our engagement with Revenue through TALC, the Institute, under the auspices of the CCAB-I also provided feedback on the judgment. While our understanding did not reflect Revenue’s interpretation in certain areas, the process provides the appropriate forum for a detailed understanding of the judgment and its implications.

Revenue has published new guidance on the registration process for Pillar Two taxes. Entities must register with Revenue for the relevant taxes within twelve months following the end of the first fiscal year in which they fall within the scope of Pillar Two taxes which includes taxes arising under the Income Inclusion Rule (IIR), the Undertaxed Profit Rule (UTPR), and/or the Qualified Domestic Top-up Tax (QDTT). The guidance outlines the relevant Pillar Two registration obligations and provides information on the registration hub and managing the various registrations. The registration hub is now live and the deadline for in-scope entities with a fiscal year ending on or before 31 December 2024 to register with Revenue for Pillar Two is 31 December 2025 Entities are also required to register for the Top-up Tax Information Return (TIR) through the registration portal, enabling them to inform Revenue whether the TIR will be filed in Ireland or by a Designated Filing Entity in another jurisdiction. Revenue issued letters to Irish Ultimate Parent Entities (UPEs) in mid-August 2025 regarding the registration process and a second phase of letters are due to be issued soon to the constituent entities of the Irish UPEs. Further details on the registration portal and the dedicated Revenue Pillar Two hub are outlined in our recent news item.

In this week’s cross-border trading corner, we bring you the latest guidance updates and publications. The most recent Trader Support Service bulletin is also available as is the latest Brexit and Beyond newsletter from the Northern Ireland Assembly EU Affairs team. Miscellaneous guidance updates and publications This week’s miscellaneous guidance updates and publications are as follows: Appendix 1: DE 1/10: Requested and Previous Procedure Codes of the Customs Declaration Service (CDS), Appendix 2: DE 1/11: Additional Procedure Codes Notices made under the Customs (Special Procedures and Outward Processing) (EU Exit) Regulations 2018, Notices made under The Customs (Import Duty) (EU Exit) Regulations 2018, Apply to delay or pay less duty on goods you import to process or repair, Apply to pay less duty on goods you export to process or repair, Import goods to the UK temporarily, Check if you can get import duty relief on goods using Temporary Admission, and Apply to import goods temporarily to the UK.

Ahead of HMRC’s Annual Stakeholder Conference which takes place in London tomorrow, the Institute has written a letter of introduction to HMRC’s new CEO setting out four key issues on its agenda. The Institute will be represented at the conference and will report back on the conference in next week’s Chartered Accountants Tax News. This year the conference theme is “Navigating the future together: the Transformation Roadmap in Action”.  The four key issues covered in the letter to JP Marks are: The Institute’s campaign for a lower rate of corporation tax in Northern Ireland, The tax burden and complexity arising from cross-border and remote/hybrid working, Tax simplification and the lack of progress in this area, and Making Tax Digital for Income Tax and the implementation of mandatory tax adviser registration from 1 April 2026. 

In a detailed miscellaneous update this week which you can read more about below, HMRC is seeking research participants for its project looking at multi-factor authentication (MFA) for agents. In other news this week: The House of Commons library has published a research briefing listing some of the most useful sources on tax law, policy and statistics, in addition to guidance for taxpayers, The latest fuel advisory rates applicable 1 September 2025 from have been published; notable in these is that there are now two advisory electric rates for company car drivers which depend on where a vehicle is charged, Today, 15 September 2025, is the deadline to opt out of winter fuel payments, which you can read more about in a previous news story, The latest schedule of HMRC Talking Points live and recorded webinars for tax agents are available for booking. Spaces are limited, so take a look now and save your place. A webinar is also taking place tomorrow on statutory maternity and paternity pay, in addition to webinars on 16 and 17 September covering the National Minimum Wage, and Check HMRC’s online services availability page for details of planned downtime and the online services affected. HMRC seek research participants for MFA HMRC is seeking agent volunteers to participate in its project on introducing MFA for agents. HMRC has therefore asked us to share the following message which provides more information: “Request for user research volunteers for MFA discussions HMRC is expanding the implementation of multi-factor authentication (MFA) for all agents and want to engage with specific agent groups about its introduction. HMRC already uses MFA to enhance the security of Government Gateway accounts for all individuals and organisations, adding an extra layer of protection. We want to work collaboratively on the introduction of MFA so we’re looking for your help in identifying agents to take part in individual user research sessions. These will provide an opportunity for us to gather insight on the working processes within different types of agents and the operational requirements they need for implementation. We would like to speak with 6-8 representatives from each of the following agent types: Group 1 – Sole practitioners and micro firms (0-9 employees), Group 2 – Mid-sized and smaller firms (10-49 employees), and Group 3 – Large agents (50+ employees). Sessions are expected to last 60 minutes running across the month of September. When responding to us please reply to: customerengagementforums@hmrc.gov.uk and include ‘MFA volunteer’ in the subject line. Please also indicate the size of the firm the volunteer represents by indicating which of the 3 groups you belong to when replying.”

With just over six months to go to the commencement of Making Tax Digital (MTD) for Income Tax, the Institute is inviting tax agents and businesses affected by this change to take a short eight question survey. The survey is being used as a temperature check to assess readiness and will be open until the end of this month. Its results will be compared with an earlier survey from April this year and will enable us to present direct evidence of the challenges to HMRC. Take the survey now. We also remind readers that the second of two CPD webinars on MTD for Income Tax takes place later this week, tomorrow Tuesday 16 September. This webinar will be delivered by HMRC’s MTD team.

In UK news, Wednesday, 26 November has been announced as the date on which the next UK Budget will be delivered and last week the Institute held discussions with local Government representatives in Northern Ireland to discuss ongoing concerns about the upcoming April 2026 changes to agricultural and business property relief, which are expected to disproportionately affect the region. In Irish news, the Fiscal Monitor for August 2025 has been released and we bring you an update from the recent TALC Collections sub-committee meeting. In International news this week, the OECD publishes a revised Transparency Framework on tax rulings under BEPS Action 5. UK 1. The Chancellor has announced that the next UK Budget will take place on Wednesday 26 November 2025. 2. Last week the Institute met with local government in Northern Ireland to highlight its concerns in relation to the April 2026 changes to two key inheritance tax reliefs. Ireland 3. The Department of Finance and the Department of Public Expenditure and Reform have published the Fiscal Monitor for August 2025 which confirms an Exchequer surplus of €3.2 billion to the end of August. 4. Read about the representations made by the Institute, under the auspices of the CCAB-I, at the recent TALC Collections sub-committee meeting. International 5. The OECD has published a revised BEPS transparency framework on tax rulings. Keep up to date with all the latest Irish, UK, and international tax developments through Chartered Accountants Ireland’s Tax Newsletter. Subscribe to the Tax News by updating your preferences in MyAccount. You can also read this week’s Post EU exit corner here.    

Revenue has updated a number guidance notes on the operation of Residential Zoned Land Tax (RZLT) to include details on the process for non- resident owners to obtain a tax registration number. The updated manuals include the RZLT Site Sale or Transfer Guidelines, the guidance on RZLT Registration and RZLT Return. The guidelines on RZLT registration have also been updated to include information on the e-linking process. This information has also been included in the guidance on the RZLT return together with information relating to the Abatement Claim Form process.

Revenue has updated the guidelines for VAT registration to include relevant application details, details on turnover and registration thresholds and the EU VAT SME scheme. Further information on the EU VAT scheme was included in our newsletter last week.