On 14 April 2025, the Council of the European Union adopted a further amendment of Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC9). The amendment will streamline filing obligations and reduce compliance burdens for companies under the Pillar 2 Directive. Member States are required to implement the Directive into national legislation by 31 December 2025.

Last week the Institute’s NI Tax Committee, chaired by Janette Burns, wrote to the Exchequer Secretary to the Treasury (XST) to express its concerns about the UK Government’s April 2026 proposals to restrict the availability of 100 percent agricultural property relief (APR) and business property relief (BPR) for inheritance tax (IHT) to a £1 million allowance. A copy of the letter has also been sent to the Chancellor of the Exchequer, the House of Lords Economic Affairs Select Committee, the House of Commons Treasury Committee, and the First and Deputy First Ministers of Northern Ireland. The Committee has also responded to the related consultation ‘Reforms to Inheritance Tax agricultural property relief and business property relief: application in relation to trusts.’ The letter to the XST highlights the particularly damaging impact of these proposals which are already being felt across the UK but which will impact disproportionately for family owned businesses and farms in Northern Ireland. Also highlighted is the need to ensure these proposals do not impact retrospectively which would damage the principle of legitimate expectation. Although the £1 million allowance will refresh every seven years on a rolling basis which will be of benefit to lifetime gifts, the proposals are especially unfair to the many owners of APR and BPR property who are elderly and/or in poor health amongst whom a common strategy is to hold these assets until death before passing these on to the next generation. Unfortunately, this cohort of taxpayers will not realistically be able to make future lifetime gifts to their children every seven years over an extended period of time to take advantage of the renewal of the £1 million allowance. Whilst recognising that difficult decisions may be necessary in the current geopolitical and economic environment, the Government still needs to do whatever it can to protect genuine business and farming activity in the UK. The value of comprehensive, wide-ranging consultation also cannot be underestimated. The consequences of not consulting are already clear with reports of farmers and business owners in deep distress. A broader review of the UK’s IHT regime, building on prior work conducted by the Office of Tax Simplification, is warranted to address concerns that the effective IHT rate falls as estates get larger. This should also examine mechanisms to target the concern that ‘non-farmers’ are currently investing in land to avoid IHT by using APR to pass assets to the next generation IHT free. At the moment, the government is focusing solely on these two reliefs leaving those who run businesses and farms facing an unexpected tax burden with little choice but to consider selling. These reliefs are not loopholes but exist to allow farms/businesses to continue trading, without penalty, when the owner dies and the next generation takes over. The Committee is urging the government to postpone the changes in order to consult wider and reframe this policy change in a way that it is more effectively targeted. However, if this is not an option, a range of potential mitigations are suggested in both the letter and the consultation reply which would curtail the impact.

Revenue has updated its guidance on Securitisation Regulation: Notification of Investment to reflect the most recent EU list of non-cooperative jurisdictions for tax purposes which was updated on 28 February 2025.

Revenue has updated its guidance on the taxation of payments made to home tutors by the Department of Education and on the tax treatment of remuneration of members of State & State sponsored committees, boards, commissions and other bodies to remove references to specific PRSI classes. The manuals also confirm that the Department of Social Protection is responsible for determining PRSI classes and the relevant contact details for any PRSI related queries are provided.

Statutory Instrument S.I. No. 69/2025 - European Union (Value-Added Tax) Regulations 2025 introduced a new basis for assessing eligibility for businesses to avail of VAT registration thresholds when determining the requirement to register for VAT in Ireland. As outlined in our newsletter of 24 March 2025, the Statutory Instrument transposed the special VAT scheme for small business into Irish law, the ‘Cross Border SME Scheme’. In addition, the Statutory Instrument also made a change to the conditions to be satisfied when determining if the turnover of a business exceeds the annual registration thresholds in Ireland. Prior to the change, VAT registration was required if turnover exceeded the relevant thresholds for goods and services in any continuous period of 12 months. Since the change, VAT registration is required where turnover exceeds the threshold limits in the current calendar year or did so in the previous calendar year. From 1 January 2025, the relevant VAT registration thresholds in Ireland for services is €42,500 and €85,000 for goods.

Revenue’s Online Service (ROS) will be down this evening from 6.00pm to 10.00pm due to scheduled maintenance.

The Minister for Enterprise, Tourism and Employment, Peter Burke recently announced the development of a new whole-of-government Action Plan on Competitiveness and Productivity, together with a range of measures aimed at enhancing business resilience and fostering competitiveness. The Programme for Government mandated the development of the Action Plan on Competitiveness and Productivity and by expediating this plan, the Government intends to align key decisions with the upcoming budgetary process.  The Government has also approved certain high-level short-term measures for implementation by May 2025, some of which are mentioned below: Enhancing International Trade Promotion: Actions will include a focus on implementing enhanced advisory supports for exporters facing disruption, developing a strategic approach to market diversification, and bringing forward a National Semiconductor Strategy. Addressing Business Costs:  Measures announced include adjusting the implementation timeline for the Living Wage to 2029 while outlining the Government’s continued commitment to the introduction of a Living Wage during its term. Amongst other measures announced, a new Cost of Business Advisory Forum will be established, and a Small Business Unit will be created. Improving Energy Infrastructure: Steps are to be taken to provide policy certainty regarding data centres, publish plans for connecting large energy users to the grid and to accelerate the deployment of critical electricity grid infrastructure. Commenting on the Action Plan, Minister Burke said: “We are living in a time of significant global change, marked by growing geopolitical tensions, trade uncertainties, and persistent cost pressures affecting businesses both large and small. To safeguard our economic future and support our enterprises, we must act decisively on the domestic factors we can influence. Therefore, the government has today agreed to fast-track the creation of a vital Action Plan on Competitiveness and Productivity, aiming to produce a draft within 12 weeks for discussion at a Ministerial Summit in July. This plan will identify concrete, actionable reforms across government to enhance our competitive edge. As part of this plan, we are implementing a range of immediate, targeted measures by May 2025. These actions focus on key areas including enhancing international trade promotion supports for firms facing disruption, addressing business costs through regulatory adjustments and targeted initiatives, and improving energy security and infrastructure delivery.”

Revenue has issued new guidance on the General Anti-Avoidance Rule and Protective Notifications providing guidance on the General Anti-Avoidance Rule (GAAR) and outlining the protective notification procedure. The manual provides guidance on the GAAR contained in section 811C TCA 1997 and it sets out the implications of entering into a ‘tax avoidance transaction’. The manual confirms that claiming a tax advantage from such a transaction can give rise to a tax avoidance surcharge, interest and additional tax arising on the withdrawal of the benefit by Revenue. Taxpayers have the option of filing a protective notice with Revenue to mitigate the consequences of Revenue assessing that the taxpayer has entered a tax avoidance transaction. Filing a protective notice affords the taxpayer a few benefits including protection from paying the tax avoidance surcharge in the event of the transaction being found to be a tax avoidance transaction under the GAAR. The new manual provides information on the protective notification procedures, including details on the forms to be completed to file a valid notification.

In Irish news this week, the US administration has announced a temporary suspension of tariffs on EU imports and a public consultation on the Research and Development tax credit has been launched. In UK news, the closing date for our short survey on Making Tax Digital for income tax is approaching and this week is your last opportunity to let us know your views on the UK e-invoicing consultation. In International news, the OECD/G20 Inclusive Framework on BEPS has issued a public statement. Ireland 1. Read about the temporary suspension of the recently announced US tariffs on EU imports. 2. The Department of Finance has launched a public consultation of the Research and Development tax credit and on options to support innovation. UK 3. There's still time to take our short survey on Making Tax Digital for Income Tax which closes next week. 4. This is your final opportunity to let us know your views on the UK e-invoicing consultation. International 5. Read the public statement issued by the Inclusive Framework on BEPS following a recent successful meeting. 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.    

Revenue has updated its guidance on the VAT Repayment Offset removing the option to offset a VAT repayment against a debt warehouse period as the debt warehouse scheme has ended.

Revenue has published new guidance on the Tax Treatment of CervicalCheck Payments outlining details of relevant tax exemptions announced by the Minister of Finance in Budget 2025. The tax exemptions relate to payments made to certain women impacted by failures in the CervicalCheck national screening programme and include payments made under the CervicalCheck non-disclosure ex-gratia Scheme, the CervicalCheck Tribunal Act 2019, and claims concluded by way of settlement and court order.

The accelerated wear and tear allowances scheme for farm safety equipment was expanded by Finance Act 2024 to provide for an expanded list of eligible farm safety equipment. The expanded scheme was launched last week by Minister for Agriculture, Food and the Marine, Martin Heydon TD, and Minister of State with responsibility for Farm Safety, Michael Healy-Rae TD. The accelerated capital allowance scheme complements grant aid which is available under TAMS3 for safety-related investments. Any grants received for qualifying equipment should be deducted from the qualifying expenditure hence only the net cost qualifies for the accelerated capital allowance scheme. A certification process applies to the scheme. Farmers who receive a qualifying certificate can avail of 50 percent capital allowances per annum on qualifying investments to be claimed over an accelerated two-year period. This compares to the standard period of eight years for plant and machinery. The allowance should be claimed on the farmer’s tax return. At the launch of the scheme, Minister for Finance, Paschal Donohoe said: “This scheme of accelerated capital allowances for farm safety equipment and the recently expanded list of eligible equipment shows the commitment of this Government to farm safety. This scheme will assist farmers in safe proofing their farms and I encourage all farmers to avail of this scheme.”