Revenue has updated its general background guidance on corporation tax. The updated guidance reflects Finance Act 2024 amendments to Start-up Relief for companies under section 486C TCA 1997. The new participation exemption for foreign distributions under section 831B TCA 1997 in also included in the revised guidance.  

Revenue has updated its guidance on the High-Income Individual’s Restriction to reflect amendments to section 485C TCA1997 introduced by Finance Act 2024. The amendments delete section 485C (1B) TCA 1997 and relevant references in Schedule 25B of the Act which were required to reflect the removal of obsolete provisions in the section dealing with the restriction on the use of capital allowances for certain leased assets.  Examples throughout the guide have also been updated to the calendar year 2024, with the 2024 credit values and rate bands now applied.

The Minister for Finance, Paschal Donohoe has recently signed the Statutory Instrument bringing into effect the changes announced in Finance Act 2024 relating to the Film Tax Credit. The enhancements announced in Finance Act 2024, referred to as the Scéal Uplift, provide for an uplift of 8 percent to the tax credit for small to medium budget feature film productions. Finance Act 2024 introduced enhancements to section 481 TCA 1997 which provides relief, by means of a corporation tax credit (Film Tax Credit), for the qualifying costs of certain audio-visual productions. The uplift will result in a tax credit rate of 40 percent for feature films for projects with a maximum qualifying expenditure of up to €20 million. As a result of the commencement order, the enhanced relief took effect from 2 May 2025 and is subject to the sunset clause of 31 December 2028 provided for in section 481 TCA 1997.

Revenue has issued a further warning of fraudulent emails, text messages and phone calls appearing to come from them seeking personal information from taxpayers.  The fraudulent messages typically relate to tax refunds and the immediate payment of tax to avoid criminal proceedings and are a phishing attempt. Revenue has confirmed that MyEnquiries, the secure online service, is used to send, receive and track correspondence. Examples of fraudulent emails and texts are included in the release. Revenue also advises individuals to reset passwords if account details have been provided in response to an email, text or phone call and to contact their bank or credit card company if bank details have been provided.

Revenue has updated the Agent's Guide to the Collector General’s Division to include new content and to update existing information. While the guidance is primarily intended to be of assistance to tax agents, it will be of assistance to any customer who transacts business with the Collector-General’s Division. The following new sections have been added to the manual: Non-resident repayment of Relevant Contracts Tax, International claims, E-linking process for agents and taxpayers, and EU VAT modernisation. The sections which have been updated are as follows: Notification of representation of properties for LPT, Late payments and interest charges, Tax relief at source (mortgage interest and medical insurance), Unregistered VAT repayments, and Due dates for submission of returns and payments. References to fixed direct debits have been removed from the guidance.

In advance of the Residential Zoned Land Tax (RZLT) pay and file deadline of 23 May 2025, Revenue has produced a series of prerecorded general information sessions on RZLT. The recordings cover a step by step guide dealing with site registration, and RZLT return and payment processes which can be accessed on Revenue’s RZLT Hub.

Revenue has updated the guidelines for charging interest on late payment through Revenue Debt Management Services. The manual now includes relevant details for capital acquisitions tax. The purpose of the guidance is to explain why interest is charged and how interest charges are raised and charged from the Debt Management Services. The title of the guidelines has also been updated and references to charging interest on fixed direct debit and balloon payments have been removed. Appendix 4, which provides details of the due dates for self-assessed taxes, has been updated to reflect current practices. 

In Irish news this week, the Department of Finance has published its first Annual Progress Report and Revenue has published new guidance on the participation exemption for certain foreign dividends. In UK news, the Institute recommends that the introduction of any UK wide e-invoicing policy should commence on voluntary basis and HMRC is no longer providing unique taxpayer references (UTRs) to taxpayers or agents over the phone. In International news, two EU Parliament subcommittees will host a joint public hearing next week on the impact of tax policies on the EU housing crisis. Ireland 1. Read about the Annual Progress Report recently issued by the Department of Finance and the Department of Public Expenditure and Reform. 2. Revenue has issued new guidance on the dividend participation exemption. UK 3. The Institute responded last week to the consultation by the UK Government  on e-invoicing, outlining the recommendation that any e-invoicing policy should commence on voluntary basis. 4. HMRC is no longer providing unique taxpayer references (UTRs) to taxpayers or agents over the phone for security reasons. International 5. Read about the upcoming public hearing on the impact of tax policies on the housing crisis 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 post EU exit corner here.  

Revenue has updated its guidance on the computation of Case I and Case II profits or gains of a company. Section 11.8 of the guidance now includes an example of correction of an error where the error has been identified prior to the filing of the tax return.

Revenue has updated its guidance on filing and paying stamp duty on Instruments to include details on amending a return filed on ROS. The guidance on charging and stamping of instruments has also been updated.   The manual on filing and paying stamp duty has been updated to outline the process to be followed when a filed stamp duty return needs to be amended by someone other than the original filer. References to ‘Using ROS offline’ have been removed as the Return Preparation Facility is now the online facility which can be used to prepare stamp duty returns. The guidance on charging and stamping of instruments has been updated to provide additional guidance on the operation of these provisions.

Revenue has updated its guidance in two of its manuals on the operation and administration of Ireland’s Pillar Two legislation. The guidance materials in question are: Part 04A-01-02 – Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union Part 04A-01-01 – Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union - Administration Finance Act 2024 provides that certain of the amendments to Part 4A TCA 1997 shall apply in respect of a fiscal year or an accounting period commencing on or after 31 December 2024. The guidance in Part 04A-01-02 has been updated to confirm that Revenue is prepared to accept the application of these provisions to a fiscal year or an accounting period commencing prior to 31 December 2024. The administrative guidance contained in Part 04A-01-01 has been updated to outline how the Undertaxed Profit Rule (UTPR) and the Qualifying Domestic Top-Up Tax (QDTT) group recovery provisions are applied where a securitisation entity is part of a UTPR and a QDTT group.

The Department of Finance and the Department of Public Expenditure and Reform have published the Fiscal Monitor for April 2025 which confirms an exchequer surplus of €2.8 billion to the end of April. This compares to a deficit of €1.2 billion recorded for the same period last year. Tax receipts collected to the end of April were €28.6 billion, which was €3.8 billion ahead of the same period last year. Excluding the once off receipts from the Court of Justice of the European Union (CJEU) judgement in the Apple State Aid case, total receipts amounted to €26.8 billion, an increase of €2.1 billion from the same period in 2024. Income tax receipts for the month of April were €3.5 billion which was €0.2 billion ahead of April 2024 receipts. On a year-to-date basis, receipts to the end of April of €11.7 billion were up by €0.5 billion (4.8 per cent), when compared to April 2024. As noted in the Fiscal Monitor, April is not a significant month for corporation tax receipts; receipts of €0.1 billion were collected in the month. On a cumulative basis, receipts of €4.9 billion were up by €2.2 billion on the same period last year. When the once-off CJEU receipts are excluded, cumulative corporation tax receipts to April 2025 amounted to €3.2 billion, ahead of the same period last year by €0.5 billion. April is a non-VAT due month and receipts in the month of €0.3 billion were down slightly on the same month last year by €38 million. Cumulative receipts of €7.9 billion were ahead by 6 percent on end-April last year.