Revenue has announced that the filing deadline for DAC2/CRS and FATCA for the 2022 filing period has been deferred from 30 June 2023 to 14 July 2023 due to filing issues in ROS. Revenue advises that taxpayers can continue to file their returns in ROS and will receive an on-screen acceptance message. However, where taxpayers experience a delay in receiving confirmation to their Revenue Record, they are asked not to re-file unless they have not received the confirmation by 7 July. Revenue’s customer service team is available to answer queries: Via MyEnquiries, selecting AEOI (Automatic Exchange of Information) and DAC2- CRS, or By telephone at +353 42 9353337.

Revenue has issued a warning of a scam SMS (text message) purporting to come from Revenue seeking personal information from taxpayers in connection with a tax refund or seeking debit/credit card details. The Revenue Commissioners never send emails or text messages requiring customers to send personal information via email, text or pop-up windows. Further information is available here.

Last week, we posted an update on the new R&D tax credit filing requirements, including the specified return. To the extent it was not clear how the new forms will apply, it was confirmed at the recent R&D Discussion Group that the new Specified Return will need to be completed and returned via MyEnquiries along with the Form CT1 2022 where: An acceleration of the second and third instalment is claimed in accordance with section 766(4D) or 766A(4C) TCA 1997 A R&D tax credit is claimed in accordance with section 766C TCA 1997 A R&D tax credit is claimed in accordance with 766D TCA 1997. As mentioned last week, the Form CT1 2023 is expected by 10 July and will include sections reflecting the updates to the R&D tax credit.

HMRC has published partial draft guidance on the multinational top-up tax (“MTT”), and the domestic top-up tax (“DTT”) included in the Finance No. 2 Bill 2023. The MTT and DTT will take effect in the UK in respect of accounting periods beginning on or after 31 December 2023. Comments should be emailed to HMRC Pillar 2 consultation inbox. Include “HMRC guidance” in the subject line, and refer to the page number (MTTxxxxx) and page title if applicable, when submitting comments. HMRC also welcomes feedback on what stakeholders might find useful in future guidance. This guidance will form a new manual hence further draft guidance will be published in due course. We also understand that HMRC is sending letters to large businesses who it believes may be within the scope of the MTT and DTT.  The multinational top-up tax is a new tax on multinational enterprise groups with annual revenue of €750 million or more. A top-up tax will be charged on UK parent members when a subsidiary is located in a non-UK jurisdiction, and the group’s profits arising in that jurisdiction are taxed at a rate below the minimum effective tax rate of 15 percent. These measures constitute the UK’s adoption of a qualifying Income Inclusion Rule and a Qualifying Domestic MTT (part of the Pillar 2 or GloBE rules). The draft guidance is partial and consists of three chapters of the HMRC guidance manual on multinational top-up tax, which exists as a standalone manual. Page 24 of the guidance includes a cross-reference table between the OECD Model Rules and the UK legislation. The three chapters are:- Introduction, which includes an overview of the taxes and guidance on chargeability; Scope, which includes guidance on excluded entities, the revenue threshold test, and the transitional CbCR safe harbour; and Administration. Additionally, the Introduction chapter includes a map between the legislation and the OECD Model Rules (at MTT09990). The draft guidance is intended to reflect the legislation in the Finance No. 2 Bill 2023 and will be updated to reflect any amendments to the legislation. Therefore, you should not assume that the guidance is comprehensive, nor that it will provide a definitive answer in every case. HMRC will use their own reasoning, based on their training and experience, when applying the guidance to the facts of particular cases.

This month’s tidbits cover several newsletters and the latest advisory fuel rates. The following newsletters are available:- Pension schemes newsletter 150 — May 2023, Charities newsletter 1 — June 2023, Employment Related Securities Bulletin 52 (June 2023), and Public service pensions remedy newsletter — May 2023; The latest advisory fuel rates, which apply from 1 June 2023, are available; The following guidance has been updated:- Confirm a tax check for taxi, private hire or scrap metal licence applications, and Complete a tax check for a taxi, private hire or scrap metal licence A new Spotlight “Dividend diversion scheme used to fund education fees (Spotlight 62)” has been published; The guidance on how to claim a refund of Income Tax deducted from savings and investments has been updated; Several publications relevant to the new Economic Crime Levy have been updated:- Prepare for the Economic Crime Levy, Register for the Economic Crime Levy, and Check if you need to register for the Economic Crime Levy.

The database supporting  application of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) has been updated and improved. The new release will allow interested parties to make projections on how the MLI modifies a particular tax treaty.

As reported in Tax News last week, the European Commission has proposed new procedures to make withholding tax more efficient and secure. The Commission has identified several problems with the existing regime, including an uneven digitalisation of tax procedures across Member States. In addition, regulation is fragmented with myriad forms applying in the various Member States. Recent estimates suggest investors are losing around €5 billion a year as a result. The new rules seek to standardise withholding tax procedures across the EU.

Recent data published on the new expanded One Stop Shop (OSS) and the new Import One Stop Shop (IOSS) indicate that Member States collected €20 billion in VAT in 2022 using the new systems. Just under 130,000 traders are now utilising the new systems.

In Irish news, the Institute represented members at TALC Collections and TALC Direct and Capital Taxes, and the Minister for Finance opens a public consultation on Ireland’s funds sector. In UK news, HMRC interest rates are increasing again, and we need your assistance with some consultation work. In International news, the European Commission has proposed new withholding tax procedures to ensure better efficiency.  Ireland The Institute represented members at TALC Collections and TALC Direct and Capital Taxes. The Minister for Finance opens a public consultation on Ireland’s funds sector. UK HMRC interest rates are increasing again. We need your assistance with some consultation work. International The European Commission has proposed new withholding tax procedures to ensure better efficiency. 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.

Revenue has updated its CREST Manual regarding the rules, procedures, practices, guidelines and interpretations for electronic share trading.  The updated manual sets out the provision in Chapter 2 of Part 6 SDCA 1999 for stamp duty to be charged on the transfer of an interest in dematerialised securities. The updated guidance also outlines the procedure that is to be followed when claiming relief from stamp duty under any of the provisions of Chapter 1 of Part 7 SDCA 1999.

Revenue has made a further update to its Tax and Duty Manual regarding the payment and receipt of interest and royalties without deduction of income tax. The updated manual exempts payments to the International Bank for Reconstruction and Development as it is one of the statutorily tax-exempt bodies.

Due to the increase in the Bank of England base rate last week, HMRC has since announced the associated increase in its interest rates. The new rates will take effect from Monday 3 July 2023 for quarterly instalment payments, and Tuesday 11 July 2023 for non-quarterly instalments payments. The two new increased rates of interest will be as follows:- late payment interest, set at base rate plus 2.5 percent, will increase to 7.5 percent from 7 percent; and repayment interest, set at base rate minus 1 percent, with a lower limit of 0.5 percent (known as the ‘minimum floor’), will increase to 4 percent from 3.5 percent.