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. 

The Department of Finance and the Department of Public Expenditure and Reform have jointly published the Annual Progress Report 2025 which incorporates the Department of Finance’s spring forecast. The report is a European legal requirement which assesses progress on the implementation of the Government’s Medium-Term Fiscal and Structural Plan. It replaces the annual Stability Programme Updates and the annual National Reform Programme in the EU budgetary cycle. The report outlines that Modified Domestic Demand (MDD) is projected to expand by 2.5 percent in 2025 and 2.75 percent next year, both of which are downward revisions compared to the autumn forecasts. The projections are prepared on the assumption that transatlantic tariffs will not be introduced and forecast a general government surplus of €8.7 billion. In an alternative scenario, which incorporates the likely economic impacts of the tariffs that are now in place, projected MDD growth is lowered to just over 2 percent this year and 1.75 percent next year. The report notes that while the economy, in aggregate terms, is undoubtedly in a strong position at present, the near-term outlook for the Irish economy is clouded in considerable uncertainty. Uncertainty in terms of trade policy, financial and commodity market developments, geopolitics and macroeconomic policies are noted as the dominant features of Irish and global economies. Navigating the challenging external environment is identified as a key priority by this Government. Commenting on the publication, Minister for Finance, Paschal Donohoe said: “The more contested and fragmented world that is now taking shape represents a serious headwind for the Irish economy which has benefited so much from the rules-based, multilateral trade system. Given the elevated level of uncertainty, it is important to stress that our assessment published today is more akin to a scenario analysis; my officials will, of course, continue to monitor incoming data and developments and update numbers accordingly.”

In every issue of The Bottom Line, we ask students for their thoughts on a particular topic. This month, we want to know: What do you think about the possible tariffs from the US? Patrycja Pisarczyk Grant Thornton Donald Trump’s tariffs, particularly on goods from China and the EU, risk destabilising global supply chains Irish companies rely on.  Businesses, especially Irish SMEs, will face significant pressure in formulating contingency plans to address potential outcomes due to the imposition of tariffs.  While this is disruptive to the economy we know today, I believe that where there is risk and uncertainty, there is also opportunity.  Such instability in the market will no doubt test the resilience and adaptability of Irish businesses, but there is potential for entering new markets and supply chains which have been disrupted by the US–China tensions, allowing firms to position themselves advantageously in this shifting landscape.  I anticipate increasing dependency on advisory and cross-border tax services. From a professional development perspective, I am excited to gain invaluable first-hand experience in the rapidly evolving economy. Varun Reddy Varala PWC In 2024, Irish goods exports hit a record €224 billion, with €72.6 billion flowing to the United States — much of it made up of pharmaceutical products.  With around 80 percent of these exports comprising medical and pharmaceutical goods, a 25 percent tariff would threaten investments, tax receipts and nearly 80,000 jobs. Ireland’s role in global supply chains raises the stakes even further.  For Instance, County Mayo is home to the world’s only facility that manufactures Botox, making it a vital player in international pharmaceutical production. It is particularly vulnerable if tariffs are widened to cover medical goods. Still, there are grounds for cautious optimism. Exports to the EU (€88.5 billion) continue to grow steadily, and Ireland’s strength in food, IT and services markets provides a valuable buffer.  While the risks are real, Ireland’s strong regulatory environment, export reputation and ability to adapt may help us weather the storm ahead. Egle Urbonaite EY The recent tariffs imposed by Donald Trump have caused some concern for people in Ireland.  In 2024, almost a third of Irish exports went to the US, which provides some perspective on how many businesses will be affected.  One of Ireland's most exported industries includes dairy products. As the US customer is paying these higher prices, sales of Irish-sourced products are expected to decline.  There is a considerable concern for US pharmaceutical companies located in Ireland, as most of them have significant dealings with the US. If they were to relocate due to decreasing profitability, this would massively impact local economies within Irish towns.  The tariffs currently imposed on Ireland aren’t significant, but the impact we may see further down the line is still of concern.   

US President Donald Trump’s sweeping new tariffs on EU imports are already reshaping trade flows. The implications for Ireland and the next generation of Chartered Accountants are immediate and complex On 2 April 2025, President Trump introduced a 20 percent blanket tariff on a wide range of European Union (EU) goods entering the United States. Trump’s rationale is to reduce the US trade deficit and repatriate manufacturing jobs. Citing what he described as “unfair advantages” enjoyed by EU exporters, Trump declared the tariffs a “long-overdue correction”. While he implemented a 90-day pause on tariff enforcement on 9 April following market disruptions, Ireland could emerge as one of the EU’s most exposed economies at the end of this pause. According to the Central Statistics Office, Ireland exported a record €72.6 billion worth of goods to the United States in 2024 – a 34 percent increase over the previous year. The US is Ireland’s largest non-EU trading partner, with most of those exports coming from the pharmaceutical and medtech sectors. Pharmaceutical exports alone reached €10.5 billion in February 2025, up from €9.4 billion the previous month, as companies rushed to beat the tariff deadline. This last-minute export surge may give way to a slump in the coming months as demand softens under the weight of new import costs. Taoiseach Micheál Martin has publicly criticised the US tariffs as damaging and unjustified. He has called for a coordinated EU response, emphasising the importance of a unified stance from the bloc. Ireland is unlikely to take unilateral retaliatory action. The tariffs may also affect investment flows. The US has long been a major source of foreign direct investment in Ireland, particularly in technology and finance. Uncertainty surrounding trade policy could cause US multinationals to reconsider a future in Ireland. Implications for Chartered Accountancy students The impact of this trade dispute goes beyond exporters and political leaders. For those looking to become Chartered Accountants, the tariffs present both challenges and opportunities Financial reporting: Accountants must accurately reflect the increased cost of doing business in financial statements. Affected firms may see reduced margins and increased volatility. This will require closer collaboration with finance teams to ensure transparency and compliance. Advisory services: Accountants will play a crucial role in helping clients reconfigure supply chains and explore alternative markets to reduce US dependency. Strategic scenario planning and cost-benefit analysis will become vital advisory tools. Tax planning: Cross-border tax considerations may shift as firms relocate operations or restructure to minimise tariff exposure. Understanding the nuances of tax will be increasingly important. Risk management: Scenario planning is more important than ever, particularly for firms in export-heavy sectors. Accountants will be called on to assess exposure, and model worst-case outcomes for business continuity. From trade policy to practice The tariffs announced by Trump on his “Liberation Day” represent a seismic shift in US-EU trade dynamics. This is a timely reminder for Chartered Accountancy students that geopolitics and trade policy are not abstract topics – they shape the very real business environments in which accountants must operate. Understanding international trade, tax and advisory skills is no longer optional for your success. Global finance is in a period of turmoil and Chartered Accountants must be just as comfortable navigating trade wars as they are auditing the books.

In order to assist readers, we have highlighted some key information resources to help you understand the impact of last week’s tariffs. There have been comments from all across the Accountancy profession, including some helpful publications providing tips for businesses as they adapt to the new global trading conditions. We also bring you the official White House publications which have accompanied the announcement of the tariffs. This includes the Fact Sheet which sets out the administration’s basis for claiming that the tariffs are a necessary tool to combat the myriad trade deficits the US operates with its global trading partners. Press releases from Government and the EU Statement by President von der Leyen on the announcement of universal tariffs by the US Statement by Taoiseach Micheál Martin on US decision to impose tariffs Statement from the Tánaiste on US announcements on tariffs House of Commons on what US tariffs on EU goods could mean for Northern Ireland Commentary from Accountancy profession KPMG - US tariffs - Understanding the implications for Ireland and the EU Grant Thornton - The implications of tariffs and trade wars PwC - US reciprocal tariffs EY – What are the implications of US President Trump’s reciprocal tariffs on global trade Deloitte - Tackling shifting tariffs: Timely tips for business leaders BDO – Tariffs & Trade in 2025: Practical Steps for Exporters and Importers Insights from Tax Research Tax Foundation - Trump Tariffs: The Economic Impact of the Trump Trade War Chartered Accountants Ireland reaction to US administration’s new tariffs Parliamentary Budget Office Trade between Ireland and the US April 2025 Official White House material Official White House Executive Order Official White House Article – “Tariffs Work – and President Trump’s First Term Proves It” Official White House Fact Sheet declaring National Emergency US International Trade Administration Official Website 2025 National Trade Estimate Report on Foreign Trade Barriers

US President Donald Trump last week announced 20 percent tariffs on all imports from the EU stating the imposition of the ‘reciprocal’ tariffs was required to address tariff and non-tariff barriers imposed by US trading partners. The Institute’s Director of Members and Advocacy, Cróna Clohisey has called the move a “regressive step” and is urging the Irish Government to work with the EU Commission to engage with the US administration in constructive dialogue. The Taoiseach, Micheál Martin released a statement noting his deep regret at the decision to impose 20 percent tariffs on imports from across the EU saying that Ireland would consider with EU partners on how best to proceed. The Taoiseach commented that the Irish economy is resilient, and that it is starting from a strong position. He is confident that we will weather the ensuing upheaval to global trade. The President of the European Commission, Ursula von der Leyen also released a statement noting the deeply regrettable choice which will massively impact the global economy. In setting out the many ways the tariffs will negatively impact citizens, she expressed a sincere openness to negotiating with the US.

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 as is the latest Brexit and Beyond newsletter from the Northern Ireland Assembly EU Affairs team. You can also read the Institute’s initial reaction to the US administration’s announcement of new tariffs last week, including commentary on the impact for Northern Ireland. The House of Commons Library has published ‘US tariffs on EU goods: What could it mean for Northern Ireland?’ setting out its view on Northern Ireland in the context of the Windsor Framework. Miscellaneous guidance updates and publications  Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service, Simplified Process for Internal Market Movements (SPIMM) and UK Carrier (UKC) Scheme: Procedure Code to Additional Procedure Code correlation matrix, Notices made under The Customs (Import Duty) (EU Exit) Regulations 2018, Maritime ports and wharves location codes for Data Element 5/23 of the Customs Declaration Service, Communications resources to help you move goods from Great Britain to Northern Ireland, and Data Element 2/3: Documents and Other Reference Codes (National) of the Customs Declaration Service (CDS).  

John O'Loughlin examines the global trade crisis sparked by Trump’s “Liberation Day” tariffs and their sweeping impact on EU exports and businesses US President Donald Trump’s “Liberation Day” announcement marked a significant and historic escalation of the US approach to international trade and tariffs. Exports from the European Union (EU) to the US are now in scope of Trump’s tariffs and some businesses will be significantly impacted by this latest round of measures. Immediate changes and impact  On Wednesday 2 April, the Trump Administration announced wide-ranging “reciprocal” tariff measures. President Trump invoked his authority under the International Emergency Economic Powers Act of 1977 (IEEPA) to address the “national emergency” posed by the large and persistent trade deficit. These measures, imposed on all global trading nations, apply a blanket additional tariff rate on all products imported into the US. As expected, the measures were applied on a country-by-country basis with the following key markets impacted by the following additional tariffs: European Union: 20% United Kingdom: 10% China: 34% Japan: 24% Switzerland: 31% Brazil: 10% Australia: 10% India: 26% South Korea: 25% In addition to the above, a further 60 or so countries will have reciprocal tariffs applied at half the rate they charge the US, according to the Trump administration. These measures are due to be implemented on 9 April. Further to these specific tariffs, all other countries not listed will be subject to a baseline rate of 10 percent, which will be imposed from 5 April and will be in addition to the standard rate of duty (most-favoured nation rate).  The Executive Order imposing the “reciprocal” tariff rates have specifically excluded certain product categories which will not be subject to these new measures. These products include: Steel and aluminium articles already subject to additional tariff measures;  Auto and auto parts already subject to tariff measures implemented on 3 April; Copper; Pharmaceuticals; Semiconductors; Lumber articles; and Energy and certain other minerals that are not available in the United States.  Regarding imports from Mexico and Canada, those that meet the US-Mexico-Canada Free Trade Agreement (USMCA) rules will not be subject to additional tariffs. However, goods that do not meet the rules under the USMCA will continue to be subject to the 25 percent tariffs imposed on 4 March. Trump’s tariffs have created a trade crisis on a global scale affecting companies across all sectors. These tariffs will remain in effect until he determines that the threat posed by the trade deficit— and underlying nonreciprocal treatment—is satisfied, resolved or mitigated. Other tariff measures As announced on Wednesday 26 March, 25 percent tariffs on imports of foreign-made cars came into effect on 3 April. The tariffs will impact cars from all countries with a value-based exception for the US value of cars covered by the USMCA. Additionally, on Monday 25 March, Trump also announced the possibility of a 25 percent additional tariff on countries purchasing oil or gas from Venezuela, with an implementation date of 2 April. As of yet, no tariffs under this measure have been imposed. Further to previous Executive Orders regarding tariffs on imports of Chinese goods, President Trump has signed an Executive Order removing the de minimis treatment for goods of Chinese and Hong Kong origin, effective from 2 May. This order imposes duties on goods valued at or under $800 which would otherwise have qualified for an import duty exemption. USTR Foreign Trade Barriers Report On 31 March, the United States Trade Representative (USTR) published its 2025 National Trade Estimate Report on Foreign Trade Barriers – a wide-ranging report highlighting foreign barriers to US exports, US foreign direct investment and US electronic commerce. Ireland is specifically noted within the report, but references are limited to commentary regarding alcohol labelling and reimbursements related to pharmaceutical products. European retaliatory measures On 12 March, the European Commission announced countermeasures in response to the US tariffs on steel and aluminium products, which it deems "unjustified".  Following a period of consultation, the EU has postponed the implementation of these measures until 15 April. These tariffs range from 10 percent to 75 percent with the majority of products falling within the 25 percent category. Additionally, the EU is set to announce further countermeasures on a wider range of goods. EU reaction On Tuesday 1 April, comments by European Commission President Ursula von der Leyen indicated that the EU is prepared to retaliate against the US, if necessary, in response to Trump's tariff hikes. “Europe has not started this confrontation, we do not necessarily want to retaliate but, if it is necessary, we have a strong plan to retaliate and we will use it,” von der Leyen said. She further emphasised the significance of the US-EU trading relationship, noting that their trade volume is $1.5 trillion and that one million American jobs rely on this trade. Von der Leyen reiterated that Europe is open to negotiations, stating, "We will approach these negotiations from a position of strength. Europe holds many cards, from trade to technology to the size of our market. However, this strength is also built on our readiness to take firm countermeasures if necessary. All instruments are on the table.” Actions for businesses In anticipation of these tariffs, companies have placed significant focus on analysing their own data and scenario planning for the impact of tariffs. With Trump’s announcement, businesses should shift their focus to tariff mitigation strategies and options, including customs origin, valuation and tariff classification. Duty relief programs should also be considered. It is expected that the EU will push ahead with its retaliatory measures and other countries may look to introduce similar measures. Trump’s executive orders also contain modification authority allowing him to increase the tariff if trading partners retaliate, or reduce the tariffs if trading partners take significant steps to remedy non-reciprocal trade arrangements and align with the US on economic and national security matters. John O'Loughlin, Partner, Global Trade and Customs, PwC Ireland

Commenting on the US administration’s new tariffs, Cróna Clohisey, Director of Members and Advocacy, Chartered Accountants Ireland said: “The announcement of 20% tariffs on imports from the EU by US President Donald Trump last night is a regressive step in transatlantic trade relations and upends the principle of open and fair trade. We urge the Irish government to work with the EU Commission to find a way to engage the US in constructive dialogue which prioritises solutions over a cycle of retaliatory measures. A further escalation in trade tensions will risk jobs, businesses and economies not just on the island of Ireland, but across the world. Without a doubt, these tariffs will cast a shadow of uncertainty over the stability of Ireland’s future corporation tax receipts with the stated aim of the tariff war being to ‘onshore’ many of the US multinationals operating overseas. As an all-island body, it is equally regrettable to see a 10% tariff announced on imports to the US from Northern Ireland, adding an additional pressure to businesses who are still navigating the complex trading landscape post Brexit. For now, we need to focus on what we can control. Prioritising Ireland’s competitiveness on the global stage will require urgently addressing our persistent infrastructural deficits. Our infrastructure is 25% less developed, on average, than other high-income European countries. This is not sustainable, particularly in the face of such protectionist measures. Now is the time to utilise the resources already at our disposal to accelerate investment in housing, water, energy and transport to best position the economy for growth - not only in terms of continued inward investment but also supporting domestic enterprises that comprise 99.8% of businesses in Ireland.”