Through our participation in the Tax Administration Liaison Committee (TALC), the Institute has consistently engaged with Revenue on the need to restructure the guidance on the reliefs for investments in corporate trades under Part 16 of the Taxes Consolidation Act (TCA) 1997, namely the Employment Investment Incentive Scheme (EIIS), the Start-up Capital Incentive (SCI) and the Start-up Relief for Entrepreneurs (SURE). We are therefore happy to share that Revenue has now restructured its guidance on these reliefs by expanding the guidance across four distinct documents. Part 16-00-02A now provides an overview of the reliefs and explains which of the other three documents is most relevant to the readers specific needs,be they a qualifying company, a qualifying investor, or an entrepreneur. Part 16-00-03 provides guidance for companies who may wish to raise risk finance using EIIS or SCI. Part 16-00-04 provides guidance for investors who seek to claim relief on investments made under EIIS or SCI. Part 16-00-05 provides guidance in relation to the income tax relief available for SURE. Readers should also be aware that the original guidance can be found here.

Last week, Revenue published preliminary results for 2025, including details of tax and duty collections, services delivered to customers, compliance timeliness, and outcomes from various compliance and enforcement initiatives. Most notably, in 2025 Revenue collected more than €106 billion in taxes and duties, along with over €34 billion collected on behalf of other government departments and agencies. In the press release accompanying the publication of the results, Revenue’s Chairman, Niall Cody, recognised the ongoing commitment of taxpayers and tax practitioners in meeting their obligations and achieving consistently strong, timely compliance rates with voluntary compliance delivering rates of 99 percent for large and medium cases and 92 percent across all other cases. The results show that Revenue completed 291,616 audit and compliance interventions during 2025 which yielded €734 million. A total of 189 tax avoidance cases were settled during the year resulting in an additional €41.7million collected on behalf of the public. Revenue is currently challenging 130 tax avoidance cases, relating to 27 transactions with 96 appeals ongoing. Readers should also be aware of the ongoing disclosure opportunity for worker arrangements which may need to have been reclassified following the Supreme Court decision in Karshan. The deadline for such disclosure is 30 January 2026 by which employers can regularise genuine cases of employee misclassification for 2024 and 2025 without incurring penalties or interest. Revenue has also advised taxpayers that 30 January 2026 is the closing date for the public consultation on the modernisation of withholding taxes, including Professional Services Withholding Tax, Relevant Contracts Tax, and expansion to the platform economy. Revenue has advised that you can complete the survey without inputting any identifying details simply by progressing to the next page. However, to the extent that you wish to engage with Revenue directly in the process, you may wish to include such identifying information.

In this week’s cross-border developments and 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. As previously recommended by Chartered Accountants Ireland, the Government announced in 2025 that there would be a permanent solution to the services provided by the Trader Support Service (TSS) beyond the end of 2025. Details of the new provider have now been announced by the Government. New permanent solution to the TSS Following the completion of a competitive procurement exercise, HMRC has appointed Netcompany as the new provider of the TSS. The TSS will remain free to use and continue to operate as normal. Users will still have access to all TSS support, including educational materials and the call centre for live queries. HMRC is working closely with Netcompany and Fujitsu to ensure a smooth transition over the course of 2026. Regular updates will be provided to users, including timely information on transferring to a new platform and any action they may need to take. Users do not need to take any action now and should continue to submit customs and safety and security declarations in the normal way. HMRC will continue to update stakeholders throughout 2026.  Miscellaneous guidance updates and publications This week’s miscellaneous guidance updates and publications are as follows: Check if you can claim a waiver for goods brought into Northern Ireland, Report payments and view your allowance for non-customs state aid and customs duty waiver claims, Customs, VAT and excise UK transition legislation from 1 January 2021, External temporary storage facilities codes for Data Element 5/23 of the Customs Declaration Service, Additional Information (AI) Statement Codes for Data Element 2/2 of the Customs Declaration Service (CDS), and Maritime ports and wharves location codes for Data Element 5/23 of the Customs Declaration Service.

In this week’s detailed miscellaneous updates which you can read more about below, HMRC has issued a response to issues raised for VAT error correction notices and the latest Agent Update is available. HMRC has also announced its revised late payment and repayment interest rates. In other news this week: The December 2025 HMRC Stakeholder Digest is now available, The Institute for Fiscal Studies has published new trends in self-employment and top incomes and a podcast on how to fix VAT, 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, and finally, Check HMRC’s online services availability page for details of planned downtime and the online services affected. VAT error correction notices During a HMRC VAT registration subgroup meeting in 2025 (the Institute is represented on this forum),  issues were raised in relation to VAT error correction notices. HMRC has responded as follows: “The online VAT Repayment tracker currently allows the user to view and track progress of all repayments due, this includes VAT repayments, officers assessments, and error correction notifications.  However as displayed below, it does not detail what contributes to a repayment, and it does not advise if a submission was made by the customer or their agent. We are speaking to our IT partners to seek improvements to what is currently shown.” Agent Update 138 Agent Update: Issue 138 is available now. Get the latest guidance and information on: ·operational activity following publication of the independent review of the loan charge, important changes to Automatic Exchange of Information: action required, get ready to file Self Assessment tax returns, mandatory tax adviser registration: policy paper published with guidance coming soon, and Making Tax Digital support and resources for agents. HMRC interest rates The Bank of England Monetary Policy Committee announced a reduction in the Bank of England base rate to 3.75 percent from 4 percent last month. As a consequence of HMRC interest rates being linked to this, HMRC’s interest rates have been reduced. These changes took effect as follows: 7.75 percent is the new rate of late payment interest from 29 December 2025 for quarterly instalment payments and 9 January 2026 for non-quarterly instalments payments, and 2.75 percent is the new rate of repayment interest from the same dates.

Ahead of the 2024/25 online self-assessment (SA) filing and payment deadline of Saturday 31 January 2026, key information and reminders are set out below. Members are also advised to contact the Institute by email if they experience any issues in the coming weeks which prevent the filing of 2024/25 SA returns before the deadline so that we can discuss with HMRC. To the extent unforeseen events arise, we may be able to engage directly with HMRC to seek appropriate accommodations (in a similar manner as last year when various storms affected members). Ahead of this year’s filing deadline, more than 4,600 festive filers escaped the turkey and tinsel on Christmas Day to file their returns with 1-1.59pm being the busiest time; maybe the brussel sprouts were on to boil? Almost 10,500 then boxed clever to file on Boxing Day. However, as at 5 January 2026, almost 5.65 million returns were still due to be filed. By way of reminder, in November HMRC published its top SA filing tips for agents in Agent Update 137. Taxpayers should also be aware of the actions they may need to take due to the in-year changes from 30 October 2024 to the rates of capital gains tax (CGT). Due to this mid-year change, HMRC's online SA filing software does not automatically calculate gains at the correct rates if a taxpayer has gains both before and after the changes. This software has not been updated and defaults to the lower pre-30 October 2024 CGT rates for all gains.  If a taxpayer made disposals of non-residential property assets on or after 30 October 2024, the following actions need to be taken: Calculate the CGT adjustment amount: the taxpayer will need to calculate the difference between the CGT due at the new (higher) rate(s) and the amount calculated by the HMRC software. Use the HMRC calculator to work out the CGT adjustment amount: HMRC has provided an online calculator to help individuals work out the CGT adjustment amount. Enter the CGT adjustment amount on the 2024/25 SA return: the resulting CGT adjustment figure needs to be manually entered into box 51 (adjustments to Capital Gains Tax) on page CG4 of the Capital Gains summary pages (SA108) of the SA return, and Attach the online calculator calculation: it is also recommended that taxpayers save the results page from the online calculator and submit this as an attachment with their SA return.  Key messages for the SA deadline and materials can be found on HMRC’s Frontify platform. As this year’s filing deadline falls on a Saturday, HMRC has also sent the below message setting out details of their support arrangements on that day. This essentially means that there will be no support via telephone on 31 January, except for a call-back service for vulnerable taxpayers. HMRC has also explained below why it is taking this approach. “What we will offer on Saturday 31 January: Significantly enhanced webchat capacity – approximately 200 advisers, compared to our usual Saturday staffing of around 20. This represents a ten-fold increase in capacity. Broader service coverage – webchat will be available across Self Assessment, the Agent Dedicated Line, Extra Support Team, Bereavement, and the Online Services Helpdesk. This is a wider range of services than we could viably staff via phone lines on a Saturday. A callback process for vulnerable customers needing Extra Support or Complex Case team assistance. 24/7 digital resources – our digital assistant and comprehensive GOV.UK guidance will remain available throughout. Why we have taken this approach: We have concluded that the best way to support customers is to prioritise adviser availability in the days running up to the deadline, while providing a comprehensive webchat service on the Saturday itself. This ensures we maintain full capacity during the critical weekdays when demand is highest, while still offering real-time support on the deadline day. Importantly, all remaining Self Assessment customers will be filing digitally, as the paper filing deadline passed on 31 October. Our communications approach: We will be clear and upfront with customers from early January, giving them time to plan ahead. From the week commencing 5 January, we will begin daily social media posts encouraging early contact and digital use, alongside clear messaging that phone lines close on Friday 30 January and reopen on Monday 2 February. On 12 January, we will include details of Saturday's webchat service in our Self Assessment payment reminder press notice, update GOV.UK contact pages, and share information through the Agent Update. From 23 January, IVR messaging will be updated to confirm no phone lines on Saturday, and on 30 January we will issue a final reminder that it is the last day for phone support. This approach gives customers who prefer phone contact time to reach us during the week before the deadline, when we have maximum staffing in place.” Ahead of the filing deadline, the Institute has also been made aware that delays are being experienced in client authorisations being processed and the client appearing on the agent’s client list. We have been advised that HMRC is aware of the issue and a fix has been deployed  for new authorisations. All older authorisations should now be appearing on client lists. Any further issues experienced should be reported to HMRC’s online services helpdesk in the first instance with recourse to the Institute by email if these continue to hamper efforts to file by the deadline.

The Chancellor has asked the Office for Budget Responsibility to prepare an economic and fiscal forecast for publication on 3 March 2026, which is being referred to as the Spring Forecast. This will be followed in Parliament with a statement by the Chancellor, known as the Spring Statement. The Institute will report on this in full when it is announced. Following on from the Autumn Budget, the House of Commons Library has published a further research briefing on the Autumn Budget and the Finance (No. 2) Bill, in addition to a research briefing on the National Insurance Contributions (Employer Pensions Contributions) Bill. Last month the Treasury Committee held an evidence session with the Chancellor to discuss the Budget.

On 23 December 2025 the Government announced that the £1 million allowance for 100 percent agricultural property relief (APR) and business property relief (BPR) for inheritance tax (IHT) will now be increased to £2.5 million from 6 April 2026. Relief will remain limited to 50 percent on the amount of qualifying assets valued above this threshold resulting in an effective IHT charge of 20 percent (i.e., half the standard 40 percent IHT rate). Details of the announcement were made in a news release published by HM Treasury on 23 December 2025. Having lobbied heavily on this issue since the 2024 Budget and throughout 2025, the Institute issued a Press Release on 23 December reacting to the announcement noting this welcome mitigation including the confirmation of transferability of the allowance between spouses. A timeline of all formal lobbying and Press Releases on this issue by the Institute since it was announced in 2024 is set out below. When combined with the transferability of any unused amount of the allowance between spouses and civil partners, another Institute recommendation that was announced at the Autumn Budget in November 2025, this effectively means that a couple will have a combined allowance of £5 million before any unused amount of their transferable nil rate band is taken into account. This would potentially increase the overall 100 percent amount on which no IHT will be payable to £5.65 million should their full £325,000 nil rate band be unused. As a result, many farms and family owned businesses in Northern Ireland will continue to receive 100 percent APR and BPR and not have any IHT liability, protecting the succession plans of these businesses for the next generation. HMRC has published an updated policy paper on this issue which also confirms that if the first spouse or civil partner’s death was before 6 April 2026, it will be assumed that the entirety of their £2.5 million allowance is unused and thus will be available for transfer to the surviving spouse or civil partner. HMRC has also published an explanatory note on the Government’s tabled amendment for this change. Clause 62 and Schedule 12 of Finance (No. 2) Bill have since been amended and the full amendment papers have been published. Finance (No. 2) Bill has now had its second reading in the House of Commons; the next stage is Committee of the whole House which is scheduled to take place today, 12 January 2026. We also understand that during an exchange in Parliament between the Exchequer Secretary (XST) Dan Tomlinson and Robin Swann MLA, it has been suggested that the ability to transfer individual allowances to a spouse/civil partner may potentially also apply to intergenerational farms owned by other family members. The Hansard exchange discussing this has also been published. At present, this is not fully clear and requires Government clarification which we will monitor. The Hansard exchange also confirms that the Government now expects to raise around £300 million from this change. The expected tax take by 2029/30 from the original policy announced in the 2024 Autumn Budget was £520 million. It remains unclear if the Chancellor intends to announce new tax increases in the Spring Forecast to cover this new deficit. However this may not be needed given the £22 billion fiscal headroom provided by the most recent Budget. The full timeline of formal Institute representations and Press Releases on this issue since the Autumn Budget in 2024 is as follows: November 2024: meeting with HMRC on Autumn Budget 2024, December 2024: press release on APR and BPR, April 2025: letter to XST on APR and BPR, April 2025: response to consultation on APR and BPR, July 2025: press release on APR and BPR, September 2025: meeting with local Government on APR and BPR, October 2025: submission to House of Lords Finance Bill Sub-Committee on APR and BPR, October 2025: Autumn Budget 2025 pre-Budget submission, October 2025: evidence session by Leontia Doran to House of Lords Finance Bill Sub-Committee, November 2025: Autumn Budget Press Release, and December 2025: meeting with HMRC on Autumn Budget 2025.  

After months of intense discussion following the announcement by the US Administration that it would be withdrawing from its previous commitments under the OECD’s global minimum tax rules under Pillar Two, the OECD has now published details of a compromise agreement which paves the way for US cooperation with the project. The new package contains details of the new Side-by-Side Safe Harbour which will see countries that operate a minimum tax system with similar policy objectives and overlapping scope as Pillar Two being granted ‘Side-by-Side’ status. The Inflation Reduction Act (IRA) in the US introduced a new corporate alternative minimum tax (CAMT) of 15 percent effective for tax years beginning after 2022. As such, the same minimum tax rate that applies to US and Irish headquartered entities. This is naturally key to ensuring that the compromise agreement does not immediately provide a competitive advantage to companies headquartered in the US over similar entities headquartered in Europe and other jurisdictions implementing Pillar Two.  From an Irish perspective, the report notes, for companies applying the Side-by-Side Safe Harbour, a qualified domestic minimum top-up taxes (QDMTTs) aligned with the Pillar Two rules will continue to apply in Ireland. Therefore, Irish subsidiaries of US-headquartered companies should continue to pay QDMTTs in Ireland with an even playing field being maintained as a result. Overall, the package includes five key components: A series of simplifications to reduce the compliance burden on both in-scope entities and tax authorities. Rules to enhance alignment of tax incentives through a targeted substance-based tax incentive safe harbour. A new Side-by-Side (SbS) Safe Harbour for companies within a group whose ultimate parent entity is located in a jurisdiction that has not implemented Pillar Two and where that jurisdiction operates a minimum tax system with similar policy objectives and overlapping scope as Pillar Two.   A commitment to taking an evidence-based stocktake to ensure that a level playing field is maintained across the jurisdictions participating in the Pillar Two project. A commitment that the qualified domestic minimum top-up tax mechanism will be the primary mechanism for ensuring that local tax bases are protected through this process. The OECD will host a dedicated webinar to support implementation of the package on 13 January 2026. 

The OECD has published a report to support jurisdictions in the design and operation of digital continuous transactional reporting (DCTR) regimes for value added tax (VAT). The report promotes greater international consistency in the development of DCTR to assist in preventing complex compliance challenges for businesses.

This week the OECD published the details of the Pillar Two Side-by-Side Package, which paves the way for US cooperation with the Pillar Two initiative. The agreement exempts US headquartered multinationals from most of the Pillar Two rules (implemented in Ireland under the EU Minimum Taxation Directive). The compromise reached will see countries that operate a minimum tax system with similar policy objectives and overlapping scope as Pillar Two granted ‘Side-by-Side’ status (SbS).   Importantly from an Irish perspective, the report notes that qualified domestic minimum top-up taxes (QDMTTs) aligned with the Pillar Two rules will continue to apply to Irish subsidiaries of US-headquartered companies. As such, QDMTTs should continue to be collected in Ireland and an even playing field should be maintained as a result.  The Inflation Reduction Act in the US introduced a new corporate alternative minimum tax (CAMT) of 15 percent effective for tax years beginning after 2022. As such, the same minimum tax rate that applies to US and Irish headquartered entities. This is naturally key to ensuring that the compromise agreement does not immediately provide a competitive advantage to companies headquartered in the US over similar entities headquartered in Europe and other jurisdictions implementing Pillar Two.  In addition to the SbS Safe Harbour, the package also brings broader simplifications, including a simplified effective tax rate safe harbour, the extension of the transitional country-by-country reporting (CbCR) safe harbour, as well as a substance-based tax incentive safe harbour. 

Today’s announcement by the UK Government of significant changes to its proposed inheritance tax reforms is a significant step in safeguarding rural communities and supporting succession planning for future generations according to Chartered Accountants Ireland. Following strong lobbying efforts in 2025, including from Chartered Accountants Ireland, the threshold for 100% relief on agricultural and business property combined will increase from £1 million to £2.5 million from 6 April 2026. Beyond this threshold, a 50% relief rate will apply, meaning couples can pass on up to £5 million of agricultural or business assets between them, in addition to existing allowances such as the nil-rate band. According to the Government, these changes mean only a small number of estates with agricultural and business assets will pay additional inheritance tax. Leontia Doran, UK Tax Manager, Chartered Accountants Ireland said "Chartered Accountants Ireland has consistently highlighted that the original proposals would have disproportionately impacted farmers in Northern Ireland. We strongly advocated for changes to ensure that genuine farming activity and family-owned businesses were not unfairly penalised. Today’s announcement is a significant step in safeguarding rural communities and supporting succession planning for future generations not just in Northern Ireland but across the UK." ENDS

In Irish news, Revenue has extended the deadline for completing the VAT modernisation and eInvoicing survey and the Institute has its say on the Finance (Tax Appeals and Fiscal Responsibility) Bill 2024. In UK news, we present the concluding part of our in-depth Autumn Budget 2025 coverage, focusing on measures aimed at closing the tax gap alongside various other announcements. We also remind readers that the deadline for submitting 2024/25 online self-assessment returns is 30 December 2025 to enable collection of tax under £3,000 via PAYE. In International news this week, the European Commission publishes a report on tax gaps in the EU.  Ireland 1. Revenue has extended the timeline for completion of the VAT modernisation and eInvoicing survey to 16 January 2026. 2. Read the Institute’s submission to the Joint Committee on Finance, Public Expenditure, Public Service Reform and Digitalisation outlining concerns on proposals included in the Finance (Tax Appeals and Fiscal Responsibility) Bill 2024. UK 3. The final part of our detailed Autumn Budget coverage highlights measures aimed at closing the tax gap and investment in HMRC together with updates on other miscellaneous measures. 4. The deadline for filing the 2024/25 self-assessment returns online to allow tax collection via the PAYE tax code is 30 December 2025.  International 5. Read about the report published by the European Commission assessing the tax gaps in the EU. 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 Cross-border developments and trading corner here.