As previously reported in Tax News, the Department of Finance published its Revised General Scheme of Finance (Tax Appeals and Fiscal Responsibility) Bill 2024, which contained, among other things, proposals to substantially alter the adjudication process at the Tax Appeals Commission. As part of the pre-legislative scrutiny process of the Bill, the Joint Committee on Finance, Public Expenditure, Public Service Reform and Digitalisation were inviting submissions from interested groups. On Friday, the Institute sent in our submission to inform the discussions. Our fundamental concern relates to the proposal that adjudication at the Tax Appeals Commission would be in private in exceptional circumstances only and that redaction of determinations would be at the discretion of the Appeals Commissioner. You can read our full submission here. Our view is that appeals heard by the Tax Appeals Commission (TAC) can be substantially differentiated from those heard by the Workplace Relations Commission (WRC): In Zalewski v Adjudication Officer and the Workplace Relations Commission, Ireland, and the Attorney General [2022] 1 IR 421 (“Zalewski”), the individual had no right to have a hearing before the WRC heard in public. It is already the case that a taxpayer can make an application to have an appeal before the TAC heard in public. Unlike the WRC, the TAC does not arbitrate between private parties (as was the case in Zalewski, which concerned the operation of the WRC). The role of the TAC is to consider and determine whether an assessment made by the Revenue Commissioners (an executive arm of the State), should be confirmed or varied. Fundamental to the operation of the self-assessment tax compliance process is the principle of confidentiality of taxpayer data. The proposed amendments to the TAC procedures must be established in light of this fundamental and legislatively enshrined principle. This starting point therefore necessitates that the fundamental principle of public hearings must be limited for cases heard at the TAC. We also note that the TAC, under its current procedural mandate, preserves a taxpayer’s right to privacy under Article 40.3.1 of the Constitution. To the extent that any amendment is made, it should ensure that a taxpayer’s right to privacy remains protected with an irrefutable right to request a private hearing and redaction of identifying information for all cases brought before the TAC.

Revenue is extending the timeline for the completion of the Large Corporates Division (LCD) VAT modernisation and eInvoicing survey to 5pm on 16 January 2026. We encourage members working in VAT-registered businesses under the remit of LCD and those advising LCD VAT-registered businesses to share their insights with Revenue and to urge their clients to complete the survey. Please note, while the survey requests the business name and tax registration number, these are not mandatory and do not need to be provided in order to complete the survey. You can leave these boxes blank and still respond. The survey has issued, on 20 November, directly to businesses through Revenue’s Online Services (ROS) and the results will inform Ireland’s implementation of the EU’s VAT in the Digital Age (ViDA) package and the implementation of eInvoicing in Ireland. Queries can be sent to VATmodernisation@revenue.ie, and all relevant updates on VAT modernisation will be published at revenue.ie/vatmod. Further details regarding the survey are included in our earlier newsletter item.

With just under four months to go to the commencement of Making Tax Digital (MTD) for income tax from 6 April 2026, the Institute is pleased to present our new MTD hub. The aim of the hub is to assist members and businesses in their preparations for this key change in UK tax administration. Read the latest news and guidance on this key change in addition to more detailed information on what MTD for income tax is, the timetable for mandation, exemptions, deferrals, how to sign up and much more. The Institute will continue to develop the hub in the coming weeks and months as policy changes are announced and as HMRC publishes tools and information to assist agents, businesses and landlords in their preparations.

The guidance on the interest limitation rule has been updated by Revenue to provide details in relation to the ‘association’ tests in the context of partnerships. The guidance is consistent with the relevant information included in the guidance on the anti-hybrid rules and guidance on the taxation of partnership. An additional appendix has been included to provide clarifications on the population of the Form CT1 with respect to the interest limitation rules.

The Central Statistics Office has published the Quarterly National Accounts for the third quarter of 2025 confirming GDP decreased by 0.3 percent in the third quarter of this year while Modified Domestic Demand grew by 2.3 per cent in the quarter. The publication outlines that exports increased by 2.1 percent while total imports rose by 10.4 percent. Personal spending on goods and services which is seen as a key measure of domestic economic activity, was up by 0.1 percent in the quarter. Commenting on the figures, Tánaiste and Minister for Finance, Simon Harris said: “Today’s figures confirm the continued resilience of the domestic economy. Modified Domestic Demand grew by 5 per cent in the third quarter on an annual basis. While this may overstate the underlying performance of the economy at present, I am encouraged by the strength of consumer spending which grew by 2½ per cent over the same period.  Alongside the robust exchequer figures released yesterday, today’s figures highlight the relatively healthy position of our domestic economy at present.”

Last week saw the House of Commons debate the Budget resolutions following which the Finance Bill was published and introduced to the House. Finance (No. 2) Bill 2025/26 had its first reading last week with second reading subsequently scheduled for 16 December 2025. The Bill, as introduced, contains the legislation for a range of announcements in November’s Budget but also features the draft legislation on the changes to agricultural property relief and business property relief from 6 April 2026. Explanatory notes to the Bill are also available. The House of Commons Library has also published a research briefing on the Autumn Budget 2025 and the Finance Bill.  The Finance Bill also includes the primary legislation for the UK’s carbon border adjustment mechanism legislation (CBAM) which will commence from 1 January 2027. More information on the UK’s CBAM is available in a policy update and factsheet. Finance (No. 2) Bill 2025/26 also includes further amendments to the UK's Pillar Two multinational top-up tax and domestic top-up tax. According to HMRC, these amendments are “those identified from stakeholder consultation or otherwise necessary to ensure the UK’s legislation remains consistent with the commentary and administrative guidance to the GloBE rules developed by the UK and other members of the OECD/G20 Inclusive Framework”. HMRC has also confirmed that the Finance Bill does not include any amendments to reflect any ‘side-by-side package’ as this is still being finalised by the Inclusive Framework. The ‘side by side package’ is a proposed political agreement which would allow the existing Global Intangible Low-Taxed Income Tax regime of the USA to coexist with the OECD's Pillar Two global minimum tax rules. The objective of this arrangement would be to exempt US parented multinational enterprises from some key Pillar Two rules.

The Pillar Two registration deadline for in-scope entities with a fiscal year ending on or before 31 December 2024 is 31 December 2025. At a recent Main TALC meeting, Revenue’s Large Corporates Division (LCD) highlighted that the number of registrations to date remains low. Revenue outlined the importance of completing registrations well ahead of the deadline and urged practitioners to ensure that any clients within the scope of Pillar Two are registered on time. Revenue had previously sent a letter to Irish companies who may be in scope of Pillar Two taxes, advising them of their registration obligations. The Pillar Two registration link can be found on the ROS homepage under ‘Other Services’. Further details are outlined in an earlier newsletter item.

Revenue has published a further warning of fraudulent emails, SMS (text messages) and phone calls seeking personal information from taxpayers. The press release outlines that Revenue has recently had sight of scam emails which claim that a taxpayer is “due an audit” and which include a link requesting the taxpayer to arrange the audit by a specified date. These messages are not from Revenue. Revenue will never contact a taxpayer by email, SMS or phone call to inform you of a tax refund or bill. Taxpayers who have provided Revenue account details in response to an email, SMS or phone call are advised to reset their password immediately. Taxpayers are advised to contact their bank or credit card provider if they have provided bank or card details.

Following the Budget, HMRC sent an email setting out key details that will directly affect tax agents, in addition to information that might be useful for their clients, or which agents may receive enquiries about. HMRC also confirmed that as set out at the Budget, the Finance Bill includes the legislation that requires tax advisers who interact with HMRC on behalf of clients to register with HMRC and meet certain eligibility conditions. This requirement was due to take effect from April 2026 but has now been delayed to take effect from May 2026. HMRC expects to publish detailed guidance on this next month. Chartered Accountants Ireland responded to the consultation on the draft legislation for this measure in September and had recommended that the measure be delayed. Our submission also recommended that the meaning of tax adviser be restricted to only require those at the highest level working in tax to be within the scope of the rules. The draft legislation now published confirms that this recommendation is largely being implemented for organisations with more than six officers (as defined). Officer is defined as follows: “(a) in relation to a company, a director; (b) in relation to a body corporate whose affairs are managed by its members, a member who exercises functions of management with respect to it; (c) in relation to a body corporate not within paragraph (a) or (b), an officer of the body whose functions correspond to those of a director of a company; (d) in relation to a partnership, a partner; (e) in relation to any other organisation, a person who exercises functions of management with respect to it.” Clauses 222 and 223 of the Finance Bill sets out details of the application process and who within that process is a relevant individual and officer whose details must be included in the application for registration.  More details are available in the associated policy paper which confirms that there will be a three-month transition period. Further details on registration timelines and the transition arrangements for specific tax adviser groups will be communicated by HMRC to stakeholders in advance. The Institute has been engaging with HMRC in the previous weeks and months as HMRC developed this amended draft legislation and will continue to do so.

Revenue has updated its guidance on deposit interest – whether a trading receipt to outline when deposit interest can be treated as a trading receipt. The guidance confirms that to qualify as a trading receipt, the funds must be considered an integral aspect of the trade. The guidance also clarifies that in general, interest earned on funds placed on deposit, which are deemed to be in excess of a company’s business needs, are not considered income taxable under Case I. This is on the basis that Revenue deems such funds as not being integral to the company’s trading activities.

Revenue has updated its guidance on small, self-administered pension schemes in relation to references in the document to Pensions Branch, High Wealth and Financial Services Division. Certain references to tangible moveable asset have also been updated and the guidance now includes the deemed distribution provisions.

Revenue has updated its guidance for trading lessors of certain short life plant and machinery. The general guidance on finance and operating leases has now been moved to the guidance on the Leasing of Machinery or Plant: General Principles of Taxation. In addition, certain outdated material relating to the taxation of specified assets has been removed.