The Commission has issued a reasoned opinion to Spain for failure to allow the deduction of directly related expenses when calculating withholding taxes on royalty payments received by non-resident taxpayers. Spain has two months to respond and take the necessary measures.

The European Commission has decided to refer Spain to the Court of Justice of the European Union on a failure to remedy an infringement in relation to the free movement of capital (Article 63TFEU) leading to a discriminatory tax treatment of non-resident taxpayers.

The European Commission has released its latest data on taxation trends in all EU countries, Iceland and Norway. The data provides statistical information on tax revenue by economic function, type of tax, level of government and implicit tax rates, enabling the assessment of tax systems from various perspectives.

The European Council has reached political agreement on a further amendment of Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC9). The amendment will streamline the filing obligations and reduce the compliance burden for companies arising under the Pillar 2 Directive, as it enables MNEs to file one top-up tax information return for the entire group at a central level.

The VAT in the Digital Age (ViDA) package was adopted on 11 March 2025 following further consultation of the European Parliament. Once enforced, Member States will be able to introduce mandatory e-invoicing under specific conditions, and improvements will be made to the Import One-Stop-Shop (IOSS) framework for improved controls.

Revenue has recently updated three other Tax and Duty Manuals. The updated manuals relate to the Form P11D, the pensions manual for overseas employment and statutory registration fees paid to the Health and Social Care Professionals Council. Details are set out below. The manual Form P11D includes further details on what is required to be included on the form, The pensions manual Overseas Employers, Overseas Employees and Employees seconded from Overseas has been updated to remove outdated material, and The manual Deduction for statutory registration fees paid to the Health and Social Care Professionals Council (CORU) has been updated to include the list of professions regulated by the CORU and the professions which have the CORU annual statutory fee included in the relevant flat rate expense allowance.

Revenue has updated the Tax and Duty Manual Schedule E expense deductions for employed consultants and non-consultant hospital doctors (NCHDs). The updates include a link to the manual General Rule as to Deduction of Expenses in Employment which provides further guidance on the following: The principles for determining tax deductibility of general expenses incurred in the performance of the duties of employment, and Flat rate expense allowances and the relevant claim process. The list of publicly funded hospitals in Ireland has been updated in Appendix 1.

Revenue has updated the Tax and Duty Manual Statement of Affairs (Probate) Form SA.2 to outline a change to the process for submitting requests for clearance from Revenue to distribute benefits to non-resident beneficiaries.  Requests for clearance must submitted individually for each beneficiary to protect the integrity of each beneficiary’s personal information. A solicitor can use a TAIN (“Transaction Advisory Identification Number”) to submit each request for clearance separately to Revenue. Information on the use of the TAIN is included in the manual.

Revenue has updated the Tax and Duty Manual  Requests for Clearance – Disposal of Land and Buildings by non-resident vendors to provide additional information and clarifications on the clearance process. The title of the manual has been updated to better reflect the detail contained within and the content has been updated to include the following details: Clarifications regarding the disposal of certain assets by a non-resident vendor, including the role of the representative and the clearance process, The clearance process for disposals of property with a secured charge. Situations where sufficient and insufficient proceeds remain, after the redemption of the charge, to settle the Capital Gains Tax liability are also addressed, Details on the clearance request process, Revenue’s action on receipt of submissions and the thirty-five working day review timeline, and A summary table is included to provide details on scenarios which may arise when dealing with disposals by non-resident vendors.

Revenue has updated the Tax and Duty Manual Tax Treatment of the reimbursement of expenses of travel and subsistence to office holders to reflect the increase in civil service subsistence rates effective from 29 January 2025.  The manual contains a link to a circular issued by the Department of Public Expenditure, NPD Delivery and Reform, on civil service rates for foreign assignments of six months or less. The manual has been updated to remove the following information which is now obsolete: The reference to reimbursement of the cost of flights cancelled due to Covid 19, Historical civil service rates for travel and subsistence which are still available in archived versions of the manual, and Details on class of allowances which have been discontinued since 2015.

Last week at a conference marking the 20th anniversary of HMRC, the Exchequer Secretary to the Treasury (XST) announced that from 31 March 2025, HMRC will be launching a new email enquiry service for agents to help escalate and resolve individual (and not employer) PAYE and Self-Assessment queries which are over four weeks old. HMRC subsequently provided more details of how the new service will work in an email to agents. For several years, the Institute has been advocating for HMRC to establish an email enquiry service for agents including in last year’s Pre-Budget submission and in a letter at the end of 2024 to HMRC on services. The Institute participates in the new HMRC Stakeholder Forum, the Customer Services for Tax Agents and Representative Bodies Working Group which aims to assess current agent services and to develop improved services for agents contacting HMRC with client queries. This new email enquiry service is an output from that forum which will continue its work including reviewing the workings of the new service. During the XST’s speech at the same event, he reflected on the Government’s vision for the future of HMRC and announced that the Government intends to raise the income tax Self-Assessment reporting threshold for trading income from £1,000 to £3,000 within this Parliament. You can read more about the XST’s speech in an email from HMRC.

The Institute will be responding to the following consultations over the coming weeks and wants to hear your views: Electronic invoicing: promoting e-invoicing across UK businesses and the public sector and Reforms to Inheritance Tax agricultural property relief and business property relief: application in relation to trusts. Email tax@charteredaccountants.ie to participate. Electronic invoicing The purpose of this consultation is to gather views on standardising electronic invoicing (e-invoicing) and how to increase adoption of e-invoicing across UK businesses and the public sector. The consultation explores how different e-invoicing approaches may align with businesses and aims to support the development of a UK approach. The consultation will run to 7 May 2025. Please share your views with us by Friday 18 April 2025. Should you wish to respond individually, responses are being accepted by submitting a form or by email to einvoicingconsultation@hmrc.gov.uk. April 2026 changes to Inheritance Tax (IHT) reliefs - agricultural property relief (APR) and business property relief (BPR) As many readers will be aware, at Autumn Budget 2024 the Government announced controversial reforms to two key IHT reliefs, APR and BPR, which will commence from April 2026. Among the changes include the following amendments: a new £1 million allowance will apply to the combined value of property that qualifies for 100 percent BPR or APR or both - after the £1 million allowance has been exhausted, relief will apply at a lower rate of 50 percent to the combined value of qualifying agricultural and business property, and the rate of BPR will be reduced from 100 percent to 50 percent in all circumstances for shares admitted to trading on a recognised stock exchange which are not ‘listed’. HMRC has now launched a limited technical consultation on this issue. Note that the purpose of this consultation is not for stakeholders to provide feedback on the overall policy change but is instead limited to examining aspects of the application of the £1 million allowance for property settled into trust qualifying for 100 percent APR or BPR. As this is a technical consultation, it is running for a shorter period of time to Wednesday 23 April 2025. The Institute is aware of the damaging impact that these reforms will have on businesses and farms in Northern Ireland and in November 2024 flagged these concerns to the Government. We would encourage members to take the opportunity to respond to this limited technical consultation and express their wider views on this damaging policy change. You can respond by using the online form or by email to aprbpr.consult@hmrc.gov.uk. The Institute again encourages you to share your views on these policy changes as we will again be writing to the Government to highlight the particular damage these changes will cause in Northern Ireland. Please email tax@charteredaccountants.ie by Friday 11 April 2025 with your views.