The OECD has published a working paper on the implications for OECD tax systems of tax arbitrage through closely held businesses. The paper finds that tax incentives to incorporate and earn capital income through corporations have increased in the last two decades. It shows that there has been an increase in incorporated businesses in many OECD countries, which has been partly driven by tax factors. The paper also finds that, in many countries, a combination of tax system features, related to corporate, dividend, capital gains, gift and inheritance taxation, provide particularly strong incentives to retain earnings inside corporations.

The Institute’s Advocacy and Voice Department is hiring a new Tax Manager. The Department is responsible for the tax and public policy agenda of Chartered Accountants Ireland. We collaborate with expert colleagues drawn from practice and industry, developing, and advocating on policy matters relating to tax, financial reporting, audit and assurance, ethics and governance, and business law. The department numbers over twenty professionals. The successful candidate will report into the Institute's Tax Leader (Head of Tax). You can find more information at the above link. If you are interested in applying, send your CV and a cover letter to hr@charteredaccountants.ie.

Revenue has updated the Tax and Duty Manual which provides information in relation to DAC2 Common Reporting Standard (CRS) reporting in Ireland. The guidance has been updated to provide further clarification on the additional guidance on ResCountry Code (section 7.5). 

The Charities VAT Compensation Scheme aims to reduce the VAT burden on charities and to partially compensate for VAT paid by the charity. Under the scheme, Revenue is to refund €10 million to charities. Revenue will notify eligible charities via their ROS inbox of the refund amount being sent to their designated account. 

Revenue has published the Special Assignee Relief Programme (SARP) statistics for 2022. These provisional statistics are based on analysis of SARP employer returns filed in respect of the 2022 tax year.  From 2012 to 2022, the number of employees claiming SARP has grown from 6 to 428, with the number of employees retained, as reported by employers as a result of the operation of SARP, growing from 6 to 1,569.  SARP provides for relief from Income Tax on 30 percent of income over €75,000 (€100,000 for an employee who arrived on or after 1 January 2023), subject to an upper income threshold, where applicable. There is no exemption from USC. PRSI is payable where the individual is not liable to social insurance contributions in their home country. School fees of up to €5,000 per annum and expenses incurred on one trip home per year, where they are paid for by the employer, are not subject to Income Tax, USC or PRSI.   The aim of the relief is to reduce the cost to employers of assigning skilled individuals in their companies from abroad to take up positions in the Irish-based operations of their employer or an associated company, thereby facilitating the creation of jobs and the development and expansion of businesses in Ireland.    In 2022, 592 employers submitted SARP Employer Returns in respect of 2,663 individuals. The estimated total cost of SARP in 2022 was €48 million, of which €0.3m and €0.5m were in relation to travel and school fees respectively. 36 percent of claimants received relief through payroll. Payroll was operated on a tax equalisation basis for 17 percent of claimants.   

Tax revenues for the third quarter of 2024 were €23.4 billion, according to the recent September Exchequer figures. The figure represents a €3 billion increase (or 14.4 percent) on the same period last year. Aggregate tax receipts in the year-to-date are €68.2 billion, ahead of last year by €6.8 billion (or 11 percent), with the over-performance largely due to corporation tax receipts. An Exchequer surplus of €5 billion was recorded to end-September.  The breakdown of tax revenues is as follows:   Income tax receipts were €24.8 billion to end-September, €1.6 billion, or 7.1 percent higher than the same period last year. VAT receipts to end-September were steady at €17.9 billion, €1.2 billion (7 percent) higher than the same period last year. Although corporation tax receipts of €1.5 billion for September were down €0.2 billion (or 13.3 percent) on the same month last year, cumulatively receipts of €17.8 billion to end-September were €3.4 billion (23.3 percent) ahead of the same period last year.  Total gross voted expenditure to end-September amounted to €72.1 billion, €7.7 billion (12 per cent) above the same period in 2023 and €2.9 billion or 4.2 per cent above profile.  Commenting on the figures, the Minister for Finance, Jack Chambers TD said:   “The tax figures published today largely continue a pattern of robust growth that we have seen throughout the year, and provide further evidence of the fundamental strength of our economy.  Of course, the stand-out feature in the tax performance has been corporation tax. Even as receipts in the year to date remain well ahead of initial expectations, the decline this month reminds us of the volatility associated with this revenue stream, and why this Government has acted to mitigate our exposure to these receipts through the establishment of the Future Ireland Fund and the Infrastructure, Climate and Nature Fund.  Budget 2025, which Minister Donohoe and I presented to the Oireachtas on Tuesday, sets out a balanced and sustainable pathway for our public finances with allows us to continue to invest in our public services and infrastructure without relying on ‘windfall’ tax revenues.” 

The Minister for Social Protection, Heather Humphreys TD, has announced that the pensions auto-enrolment scheme will begin on 30 September 2025. The Institute supports the introduction of auto-enrolment but remains concerned with its impact on small businesses.  In last week’s Budget, it was announced that Finance Bill 2024 will provide for the taxation of the Automatic Enrolment Retirement Savings Scheme (referred to as AE). According to the Budget publications, the tax treatment “aligns as much as possible with that of Personal Retirement Savings Accounts (PRSAs), other than for employee contributions.” Employer contributions will be tax relieved, the growth in the AE funds will be exempt from tax and the AE funds will be taxed on draw down, other than the 25 percent tax free lump sum. The lump sum will be able to be taken tax free up to €200,000, will be taxed at 20 percent between €200,000 and €500,000 and taxed at 40 percent above €500,000. As the State will be making a direct contribution for employees within the AE scheme, no tax relief will be provided for employee contributions to AE.    

The Parliamentary Budget Office (PBO) has published its Preliminary Review of Budget 2025. This publication provides a summary review of Budget 2025, including a distributional analysis of budgetary measures, summaries of key spending and tax measures, key economic considerations and other issues.  A Pre-Budget 2025 Ready Reckoner is also available which illustrates the estimated annual cost of various tax and welfare options. In addition, the PBO has produced a new summary interactive data visualisation on spending issues which can be found here (please note this link leads to an external website, not the PBO webpage). This will allow you to explore the projected gross voted expenditure for 2025.  And finally, the Parliamentary Budget Office has also published an information note on inheritance tax which provides an overview of Inheritance Tax in Ireland, in light of the current discussion and commentary on the matter.   

Revenue has published its Budget 2025 summary, detailing key measures in this year’s budget, together with its Pre-Budget 2025 Ready Reckoner which illustrates the estimated annual cost of various tax and welfare options.

After Budget 2025 took place last week, the team at Chartered Accountants Ireland have been busy analysing the key measures and providing analysis and commentary in the media: Our full summary of all the key measures announced as part of the Budget package is available on the Institute's dedicated Budget 2025 landing page, Read our press release reacting to the Budget announcement, The Institute’s Director of Advocacy and Voice, Cróna Clohisey, appeared on a number of radio stations covering the Budget including RTÉ Radio 1’s News at One, the Nine till Noon Show on Highland Radio (from 14:55 into show podcast) and C103’s Cork Today show with Patricia Messenger (from 52:50 into show podcast), and Listen to our additional Budget coverage in the special Budget 2025 episode of the Accountancy Ireland podcast. Further commentary and analysis will also feature in this month’s edition of Accountancy Ireland.

The OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) has published a Model Competent Authority Agreement to facilitate the implementation of its political commitment on Amount B of Pillar One. This practical tool is designed to be particularly beneficial for jurisdictions with limited resources and data availability.

On 2 October, the EU and Norway signed an agreement to amend their existing cooperation agreement on aspects of administrative cooperation, the fight against fraud and assistance on recovery of claims in the field of VAT. The new agreement will provide the partners with new cooperation tools.