As previously outlined in Chartered Accountants Tax News, HMRC is consulting on potential reforms to its behavioural penalty regime. The consultation is open until 18 June 2025 and seeks views on options to ‘simplify and strengthen’ the behavioural penalty regime for inaccuracies and failures to notify. The Institute will be responding to the consultation and is seeking your views on the proposals. Contact us by email before Monday 9 June to share your feedback. HMRC has been holding workshops on the proposed changes and has also provided a useful document summarising the proposals an overview of which is set out below. For failure to notify penalties, HMRC is proposing to remove the timing of disclosure as a factor in determining the relevant penalty ranges and to remove the narrower penalty ranges. There are also proposals to combine consideration of the type and quality of disclosure into one step, so that there is one set of headline rates. ‘Telling’ and ‘helping’ would be combined into one category to reduce overlap. For deliberate and repeated non-compliance, the potential changes are: increased penalty rates for all deliberate behaviour (e.g. same level as category 2 offshore penalties), a new higher tier of penalty rates for repeated deliberate non-compliance (e.g. at the same level as category 3 offshore penalties) and the potential for higher rates to be 'reset' for new occurrences in the future, the merger of ‘deliberate but not concealed’ and ‘deliberate and concealed’ into a single ‘deliberate’ category, and to codify ‘deliberate’ in penalty legislation, e.g. regarding intent, blind-eye knowledge, and, potentially, recklessness. There are also proposals for offshore penalties and penalty suspension. Alternative approaches are also considered as are a range of potential new non-financial penalties, many of which are very concerning.  

1 in 4 SMEs surveyed by Chartered Accountants Ireland in April reported that their business has lost employees or seen prospective employees unable to take a role due to the unavailability of affordable housing. This is evidence of the economic impact the housing crisis is now having according to the Consultative Committee of Accountancy Bodies – Ireland (CCAB-I), the umbrella group for professional accountants, as it published its 2026 Pre-Budget submission today.   The OECD has noted that Ireland’s housing stock lacks the flexibility to meet the increasing demand for housing, and only last Tuesday, the Economic and Social Research Institute (ESRI) told the Oireachtas Committee on Housing that there will be no major uptick in housing supply in 2025 and 2026. CCAB-I notes this market failure, and calls for a targeted, time bound and regularly reviewed tax intervention to correct it.   Cróna Clohisey, Director of Members and Advocacy at Chartered Accountants Ireland said  “Viability of certain construction projects, namely apartments, student accommodation, and independent living facilities has been cast into sharp focus in recent months, with knock on impacts on the costs of rent, availability of student accommodation and the lack of options for downsizers. Recent data from the CSO shows that there was a drop of 24% in apartment completions from 2023 to 2024.   “October’s Budget should include tax measures to stimulate the development of such dwellings, but they need to be targeted, time-limited, and regularly reviewed to ensure that they are cost effective and do not repeat the mistakes of the past. We welcome the opportunity to discuss with government how tax might work as a lever in this regard.”    Regulatory burden  57% of SMEs surveyed by Chartered Accountants Ireland last month cited regulatory compliance as the area they most need help from the government in tackling (rising to 75% amongst small practices). In its Pre-Budget submission, CCAB-I identifies key areas where the intersection of tax law and administration are loading uncertainty and burden onto businesses, and calls for the following measures to be considered in Budget 2026:  Key proposed simplification measures   Simplify tax filing by introducing a single pay-and-file date for capital gains tax aligned with the annual income tax return.   Simplify the reporting of tax-free small benefits and expenses (the Enhanced Reporting Requirements rules) by replacing real-time reporting with monthly or quarterly returns. CCAB-I also recommends that penalties of €4,000 that are potentially chargeable where a reportable item is missed are made proportionate with the fact that the payments are non-taxable.   Introduce legislation enabling businesses to provide their staff with reasonable levels of hospitality while working without having to apply a benefit-in-kind tax charge. This would provide much needed certainty to business as to what they can provide in terms of lunches and teas and coffees and would critically support the local economy and hospitality sector. As we operate within a self-assessment tax system, employers should be empowered to determine what is a reasonable accommodation.  Cróna Clohisey, Director of Members and Advocacy at Chartered Accountants Ireland said  “A single pay-and-file date for capital gains tax aligned with the annual income tax return would alleviate the administrative burden of what is a low-yielding tax. 2024 Exchequer receipts from CGT accounted for approximately €1.7 billion, only 1.6% of the total tax receipts in that year.   “There is similar scope to ease administrative burdens for SMEs when it comes to the reporting of tax-free small benefits and travel expenses. The requirement to report these benefits “on or before” the time they are made or paid is excessive and should be replaced by monthly or even quarterly reporting. For example, in order to reduce the number of returns and the administrative headache of this requirement, many businesses now only reimburse travel expenses to workers on the same day as payroll. This means workers can be out of pocket for longer.  “Our research also shows that the regulatory compliance burden is particularly acute for SMEs with fewer than 50 staff; 35% have sought advice on how to reduce this burden, and they are the least likely to be able to shoulder it.”  Measures to support SMEs   The Programme for Government 2025 committed to rigorously implement the SME test to scrutinise every new piece of legislation and regulation for its impact on SMEs and examine the regularity of SME reporting and filing requirements.  CCAB-I calls for consideration to be given to enhancing the R&D tax credit regime for SMEs which has played an important role in promoting innovation and job creation in Ireland. The existing regime is limiting for the SME sector due to the restrictions on relief available for third party costs, and the use of third parties to carry out research and development on behalf of the SME is an indispensable option for Ireland’s SMEs. The automatic qualification for the R&D tax credit for SMEs in receipt of RD&I funding from Enterprise Ireland would also benefit the sector and remove complexity and uncertainty in this area.   Businesses are facing substantially higher employment costs, so CCAB-I is also asking that Government commits to no further increases in the rate of Employers’ PRSI for the next four years. Incremental increases across all classes of PRSI are planned up to 2028. Consideration should also be given to reducing the rate of Employers’ PRSI on minimum wage workers by 1.5% to help with the initial costs of pension auto enrolment which will likely come in next year.   Clohisey concluded:  “According to research we conducted last month among SMEs, 3 in 4 (77%) said that business costs have increased in the past six months, with staff costs the biggest challenge. There is anecdotal evidence that increases in minimum wage are causing employers to reduce hours to offset the increased costs, so committing to no further increases in the rate of Employers’ PRSI for a set period of time would go some way in trying to stem increasing labour costs.”  ENDS  Pre-Budget Submission 2026: Addressing the ongoing housing shortage

In Irish news this week, the Institute has responded to the public consultation on the Research and Development tax credit and Revenue has announced an extension to the 2025 Residential Zoned Land Tax filing deadline. In UK news, tomorrow is the deadline for issuing a P60 for the 2024/25 tax year and in this week’s miscellaneous updates, MPs are calling on the Government to delay its planned reforms to agricultural property relief and business property relief. In International news, the OECD has published updated transfer pricing profiles. Ireland 1. Read the response by the Institute, under the auspices of CCAB-I, to the public consultation on the Research and Development tax credit and on options to support innovation. 2. Revenue issued a press release confirming an extension to the deadline for filing the 2025 Residential Zoned Land Tax returns. UK 3. Tomorrow is the date by which all employees should receive a P60 for the 2024/25 tax year. 4. This week’s miscellaneous updates features a wide range of issues, including news that a committee of cross-party MPs is calling for the Government to delay its proposed curtailments of agricultural property relief and business property relief, which are due to take effect from 6 April 2026. International 5. Read about the updated transfer pricing country profiles published by the OECD. 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.

In this week’s miscellaneous updates: The controversy and disquiet over the Government’s plans to restrict the availability of 100 percent agricultural property relief (APR)/business property relief (BPR) for inheritance tax (IHT) continues to rumble on, The National Audit Office (NAO) has published a report on collecting the right tax from wealthy individuals, HMRC has been busy issuing further communications regarding the UK’s Pillar Two rules, HMRC is seeking feedback on the Senior Accounting Officer (SAO) notification and certificate submission process, A new online interactive tool has been launched to help businesses and individuals understand HMRC compliance checks, Read an article from KPMG summarising the tax implications of the UK’s recent trade deals with India and the US, and HMRC has confirmed that Measuring Tax Gaps 2025, which will provide an estimated tax gap for 2023/24, will be published next month on 19 June. The latest schedule of HMRC Talking Points live and recorded webinars for tax agents is also 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. Government Committee of MPs says delay IHT reforms  A report by the cross-party Environment, Food and Rural Affairs Committee is calling for the Government to delay announcing its final APR and BPR reforms until October 2026, to come into effect in April 2027, saying a pause in the implementation of the reforms “would allow for better formulation of tax policy and provide the Government with an opportunity to convey a positive long-term vision for farming.” It would also protect vulnerable farmers who would have “more time to seek appropriate professional advice”.  In April, the Institute’s NI Tax Committee wrote to the Government on the same issue and also told the Government that the reforms need to be postponed in order to consult wider and reframe this policy change in a way that it is more effectively targeted. If reform is not an option, a range of potential mitigations were suggested in the letter which would curtail the impact.   The Institute also responded in April to the related consultation ‘Reforms to Inheritance Tax agricultural property relief and business property relief: application in relation to trusts.’  National Audit Office report on collecting the right tax from wealthy individuals  The NAO has published its report on collecting the right tax from wealthy individuals which examines the extent to which HMRC is well placed to support wealthy individuals to pay the right tax and intervene in good time if people get things wrong.   The report concludes that although wealthy people contribute significant amounts of tax revenue to the Exchequer, the complexity of their affairs makes it more difficult to get their taxes right and presents more opportunities to deliberately not pay enough.   In response to this concern, HMRC now publishes annual estimates of the tax gap for wealthy individuals, which it estimates to have been stable and low. According to the NAO, “HMRC deserves credit for increasing the amount of compliance yield. Its move towards more upstream casework has been an important innovation and has resulted in improved returns.” However, the scale of the increase in compliance yield from the wealthy raises questions about whether underlying levels of wealthy non-compliance are higher than HMRC previously thought.  “There is too much uncertainty around the tax gap estimate for this group, notably for offshore wealth, to be confident that non-compliance is not far higher than HMRC has detected. HMRC is working to improve its estimate of the wealthy tax gap.”  Pillar Two letters  HMRC recently wrote on Pillar Two to businesses who do not have a Customer Compliance Manager (CCM). The letter contains information on Pillar Two registration and reporting requirements, OECD standardisation, and updated HMRC guidance.  SAO notification and certification – feedback wanted  HMRC is seeking feedback on its SAO notification and certificate submission process as it working on a project to build a new digital service for this via a short survey. According to HMRC, responses to the survey are confidential and will only be used for internal HMRC research purposes. 

The latest UK tax tidbits features recent HMRC bulletins and newsletters in several areas. Employment related securities bulletin 60 (April 2025), Send an Employer Payment Summary using Basic PAYE Tools, Responsibilities for employment businesses working with umbrella companies, Working through an umbrella company, Preparing for the Multinational Top-up Tax and the Domestic Top-up Tax, Multinational Top-up Tax and Domestic Top-up Tax, Our governance, HMRC email updates, videos and webinars for Self Assessment, Compliance checks: Automatic Exchange of Information obligations — CC/FS46, Check if a business is registered for money laundering supervision, Insolvency practitioner bulletin 5 (2025): excise and insolvency, HMRC email updates, videos and webinars for tax agents and advisers, HMRC email updates, videos and webinars for the Construction Industry Scheme, Factsheet: Carbon border adjustment mechanism (CBAM), Apply for healthcare cover in the EU, Iceland, Liechtenstein, Norway or Switzerland (CA8454), Customs civil penalties, Check the status of tax policy consultations, Inheritance Tax: domicile outside the United Kingdom (IHT401), Pensions schemes newsletter 169 — April 2025, Help to avoid errors in claims for plant and machinery allowances — GfC5, List of community amateur sports clubs (CASC) registered with HMRC, HMRC email updates, videos and webinars if you’re self-employed, Register with HMRC for an agent services account, Residence, domicile and the remittance basis: RDR1, Changes in your annual allowance following the public service pensions remedy, Recognised stock exchanges, Changes to lifetime allowance charges following the public service pensions remedy, Check how your lifetime allowance is affected by the public service pensions remedy, How voluntary contributions are affected by the public service pensions remedy, Find payroll software that is recognised by HMRC, Complaint Handling Guidance, and Detailed tax guidance for charities.  

In this week’s post EU exit corner, we bring you the latest guidance updates and publications relevant in the post EU exit environment. The most recent Trader Support Service bulletin is also available. The latest Brexit and Beyond newsletter received last week from the Northern Ireland Assembly EU Affairs team contains a useful summary of the key takeaways from the new partnership agreement announced during the UK and EU summit in London. The newsletter will be published here in due course. As part of this, the UK and EU have “agreed to work towards a deal that could significantly reduce checks on goods moving from Britain to Northern Ireland”. The Northern Ireland Office has also issued a press release reacting to the new partnership agreement and recent trade deals.  Miscellaneous guidance updates and publications  Simplified Process for Internal Market Movements (SPIMM) and UK Carrier (UKC) Scheme: Procedure Code to Additional Procedure Code correlation matrix, Authorisation type codes for Data Element 3/39 of the Customs Declaration Service, Simplified Process for Internal Market Movements (SPIMM) and UK Carrier (UKC) Scheme: terms and conditions, Simplified Process for Internal Market Movements (SPIMM): Category of goods guidance, Additional Information (AI) Statement Codes for Data Element 2/2 of the Customs Declaration Service (CDS), Simplified Process for Internal Market Movements (SPIMM) and UK Carrier (UKC) Scheme: Navigate the Customs Declaration Service Declaration Instructions, Simplified Process for Internal Market Movements (SPIMM) and UK Carrier (UKC) Scheme: Declaration Category Data Sets, Simplified Process for Internal Market Movements (SPIMM) and UK Carrier (UKC) Scheme: Declaration Category Data Sets, Simplified Process for Internal Market Movements (SPIMM) and UK Carrier (UKC) Scheme: Customs Simplified Procedures Guidance, Simplified Process for Internal Market Movements (SPIMM) and UK Carrier (UKC) Scheme: Procedure Codes, and Simplified Process for Internal Market Movements (SPIMM) and UK Carrier (UKC) Scheme: CDS Declaration and Customs Clearance Request Instructions. 

Whether employees are working from home or away, find out how to deal with reimbursed expense payments and benefits paid by attending a HMRC webinar in the coming weeks. Phones, internet and homeworking  For information about homeworking expenses, register for HMRC’s webinar, which provides an overview of the tax and national insurance treatment when an employer: provides a mobile phone or reimburses for business use of a personal mobile phone, provides broadband in an employee’s home, or pays towards it, and provides homeworking expenses to its employees. Travel Register for HMRC’s webinar to find out about the tax treatment of:  travel and subsistence payments to employees, mileage payments for employees using their own vehicle, benchmark and bespoke scale rates, and keeping records and sending reports to HMRC. For information about 'PAYE Settlement Agreements (PSAs)' choose from HMRC’s playlist of short videos available on HMRC’s YouTube channel. 

As we reminded readers last week, the deadline for employers to provide employees with their P60 for 2024/25, either on paper or electronically, is Saturday 31 May 2025. The P60 summarises the employee’s total pay and deductions for the year. By that date, employers must give a P60 to all employees on payroll who were working for them on the last day of the tax year (5 April 2025). If an employer is exempt from filing payroll online, copies of P60s can be ordered from HMRC.    

The OECD has published updated transfer pricing country profiles which reflect the current transfer pricing law and practice of 11 jurisdictions including, for the first time, profiles of Azerbaijan and Pakistan. The publication includes new sections addressing hard-to-value intangibles and the simplified approach for baseline marketing and distribution activities.

On 24 June, the European Commission will host a half-day hybrid event to mark the publication of the 2025 Annual Report on Taxation. This year’s theme, “Fair and effective taxation: Strengthening compliance and progressivity”, will consider how tax policy can promote fairness, strengthen compliance, and support sustainable public finances.

Revenue has updated its  guidance to Charities and sports bodies on making an online application for a tax exemption. The guidance now reflects changes to the Charitable Donations Scheme whereby, with effect from 1 January 2025, the two-year waiting period for eligibility for the scheme no longer applies.  

The European Commission has launched a call for proposals for EU action grants in the field of taxation. The two grants involved aim to ensure the involvement of research institutions in the design and implementation of EU actions to fight the tax gap, in addition to contributing to the design of efficient tax systems.