This month HMRC is continuing with preparations for Making Tax Digital (MTD) for income tax by issuing the first batch of mandation letters based on 2024/25 self-assessment (SA) returns which have already been filed. The template of the letter is available here. Disappointingly, agents will not receive a copy of the letter sent to their client hence it is important that agents take steps to identify anyone who will be receiving a letter this month and make contact with them as soon as possible (the letter does prompt the taxpayer to share this with their agent). HMRC has also published an update on its MTD for income tax trial and we have been asked to remind you about HMRC’s agent outreach campaign for MTD. Mandation letters Sole traders and landlords who had already filed their 2024/25 SA return by the end of August 2025 are the first to receive a mandation letter from HMRC that they must comply with MTD for income tax from 6 April 2026. This is on the basis that their 2024/25 SA return included gross income from sole trade self-employment and property of more than £50,000. A further batch of mandation letters for anyone meeting these criteria but not filing their 2024/25 SA return until after 31 August 2025 but on or before 31 January 2026 will not be sent until February and March 2026. Although HMRC will be sending out mandation letters, HMRC is reminding taxpayers that it is their responsibility to: check if they are required to comply with MTD income tax from April 2026; and sign up for MTD income tax. As sign up is not automatic, if a taxpayer believes they are mandated but they do not receive a mandation letter, they should still sign up. HMRC has published guidance for taxpayers and for agents on how to sign up. We expect that towards the end of November 2025, HMRC will also send a letter to all unrepresented taxpayers who have not yet filed their 2024/25 SA tax return to remind them of the April 2026 start date for MTD income tax. These are not mandation letters but are prompt letters which are being sent on the basis of the 2023/24 SA return if this shows gross income exceeding £50,000. Trial update On the MTD trial front, the MTD testing update bulletin sets out progress made to date, provides answers to frequently asked questions and encourages participants in the trial to give their views by completing a survey.  According to HMRC, almost 2,100 successful quarter one submissions for 2025/26 have been made. A reminder was also issued to participants about the second cumulative quarterly update which were due for filing by 6 November 2025. Agent outreach campaign reminder HMRC has also asked us to remind you about the agent outreach campaign which we told you about in Chartered Accountants Tax News on 1 September. Agents can check the authenticity of this service here: Check if an email you've received from HMRC is genuine. Testing by HMRC indicates that completing the agent outreach form takes circa 2 minutes. When completing the form, agents are asked to:  Give permission to be contacted by HMRC by email, Indicate how many clients they have for testing and mandation sign ups, and  Express an interest in a one to one conversation with HMRC about MTD readiness and testing. To access the form, agents should sign in with the Government Gateway ID and password linked to their Agent Services Account (ASA). Note that if an agent does not yet have an ASA, they can still complete the expression of interest form by signing in with their Government Gateway ID and the password associated with their existing HMRC online services for agents account (agents will need to manually provide contact details when using this method). 

Revenue has issued updated guidance on the taxation of community midwives engaged by the Health Service Executive (HSE), confirming that the framework established in the Supreme Court judgment in Karshan (Midlands) Ltd t/a Domino’s Pizza [2023] IESC 24 should be applied by the HSE when determining the employment status of midwives. Two new sections have been added to the guidance: section three outlines the tax treatment applicable to community midwives classified as HSE employees, while section four provides guidance for those regarded as self-employed.

The Department of Finance published the Revised General Scheme of Finance (Tax Appeals and Fiscal Responsibility) Bill 2024 last week proposing a number of changes to the legislation governing the tax appeals process and the Tax Appeals Commission (TAC). The Bill contains some substantial proposals, not least of all is the reconsideration of tax appeals being held in camera as a matter of course (discussed in more detail below). Included in the changes is the provision to allow the Appeal Commissioners to meet at least twice annually and contingency provisions regarding the management of the Commission in the absence of a chairperson. Regarding the current practice of holding tax appeals in camera, the Bill also includes proposed amendments arising from the 2021 Supreme Court judgment in Zalewski v the Workplace Relations Commission (“Zalewski”) in which the majority held that the exercise of powers by Adjudication Officers pursuant to the Workplace Relations Act, 2015 as amended (‘the 2015 Act’) was the administration of justice within the meaning of Article 37 of the Constitution. The judgment in Zalewski concerned the appropriateness of proceedings being held in camera, and the following passage reflects one of most significant proposals in the Bill: “While there may be cause for hearings to be held ‘in camera’, per request of the parties to an appeal, in line with Zalewski it is appropriate that Appeal Commissioners have discretion to direct that an appeal should be heard ‘in camera’ on the request by a party or parties to an appeal, or to direct that an appeal should be heard in public where they believe it is in the interests of justice to do so.”

The ‘Pay and File’ deadline for ROS customers is Wednesday 19 November 2025, and the ROS Technical Helpdesk will provide extended opening hours this week. The phonelines will be open until 8pm on Monday and Tuesday and until midnight on Wednesday.

Last week the Irish Fiscal Advisory Council (IFAC) published an analytical note outlining the potential impact of US tariffs and other policy changes on Irish corporation tax receipts. The paper outlines that corporation tax now represents well over a quarter of Ireland’s total tax receipts, with approximately three-quarters of this revenue coming from large US multinationals. One of the key findings of the paper is that most of Ireland’s largest corporation tax contributors have not yet been directly affected by tariffs. The paper notes that the technology and manufacturing (primarily pharmaceuticals) sectors account for about 87 percent of the corporation tax paid by major US owned firms in Ireland. The analysis also finds that short term corporation tax receipts could be even higher, as one major pharmaceutical company accelerated exports to the US ahead of anticipated tariffs. In the paper, IFAC outlines that corporation tax revenues have become increasingly uncertain, with potential for significant fluctuations in the coming years. The note describes that while tech and pharma profits appear strong for now, tax receipts are becoming more concentrated in these sectors and this represents a risk heightened by possible future changes in US and international tax, trade, and industrial policy.

EU  Member States have agreed to abolish the €150 customs duty threshold, whereby customs duties will apply to all goods entering the EU. The Council also committed to developing a simple, temporary solution to levy customs duties on such goods as soon as possible in 2026 until the EU Customs Data Hub becomes operational in 2028.

A delegation from the European Parliament’s Tax Matters Subcommittee recently visited the US to meet with representatives of key institutions, including the US Department of the Treasury, Congress, and the United Nations, as well as with other stakeholders. Among the topics discussed were the G7/G20 ‘side-by-side approach’ for the OECD's Pillar Two system and the US GILTI/NCTI minimum corporate tax system, international tax reform at the UN level, digital services taxes, and the fight against tax evasion and tax avoidance.

The OECD has published the 2025 Tax Administration report. A key focus of this edition is a 10-year perspective on the evolution of tax administration and how the rise of artificial intelligence is shaping the future of tax administration.

In Irish news, Revenue has issued updated guidance on the Key Employee Engagement Programme (KEEP) and the Fiscal Monitor for October 2025 has been released. In UK news today, HMRC launches its refreshed mobile app as part of last week’s Talk Money Week and we bring the usual miscellaneous updates, as well as our regular cross-border developments and trading corner. In International news this week, the EU heads of tax administration reaffirm their commitment to cooperation between Member States. Ireland 1. Revenue has recently published updated guidance on the Key Employee Engagement Programme (KEEP) clarifying the limits applicable to a qualifying share option.  2. The Department of Finance and the Department of Public Expenditure and Reform have published the Fiscal Monitor for October 2025 which confirms an Exchequer deficit of €0.9 billion to the end of October. UK 3. HMRC has introduced an updated mobile app which taxpayers are being encouraged to use to access information on tax, National Insurance, and state pensions. 4. Read about recent cross-border developments and other miscellaneous updates. International 5. The annual summit of EU Tax Administrations was held last week and attended by representatives from EU member states. 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 guidance on Relevant Contracts Tax for Principal Contractors to include links to related resources to assist in the determination of the employment status of subcontractors.

Revenue has updated guidance on PAYE settlement agreements  to include a new section  relating to the repayment of overpaid income tax, PRSI and USC in respect of prior years. Where the taxpayer (in this case, the employer) has overpaid an amount of tax under the settlement agreement a claim for repayment can be made subject to the four-year time limit. Revenue intends contacting taxpayers who entered into settlement agreements for the tax years, 2021, 2022, 2023 and 2024. Employers seeking a refund must review the correspondence received from Revenue, write to the appropriate Revenue division in line with the instructions included in the correspondence and include all requested documentation. Each refund claim will be assessed individually based on its specific facts and circumstances and if a refund is approved, Revenue confirms in the guidance that interest of 0.011 percent per day will be paid from the date the tax was originally paid until the refund is issued under Section 865A(1) TCA 1997. The example in the guidance has also been updated to reflect PRSI rates applicable from 1 October 2025.

Revenue has updated its guidance on income tax relief for health insurance covering medical and /or dental benefits to outline an administrative practice that will take effect from 1 January 2026.  From this date, Revenue will accept that the standard rate of tax, currently 20 percent, will apply to all health insurance policies providing medical cover. This rate will be applied to the lesser of the premium paid or the applicable cap. Prior to 1 January 2026, where a health insurance policy covers both eligible and ineligible benefits for income tax relief purposes under section 469 TCA 1999, a blended rate of tax relief is applied. The pre-1 January 2026 position will continue to apply to health insurance policies providing dental cover. The guide provides examples of the pre and post 1 January 2026 position in section two. From an administrative perspective, the guidance has been renamed and details relating to the tax treatment of premium refunds made due to Covid-19 has been removed as it is no longer relevant. Revenue contact details in respect of claims by authorised insurers has also been updated in the guidance.