In this week’s Sustainability/ESG bulletin, read about support measures to help businesses in Ireland and Northern Ireland impacted by recent flooding. Also covered is Ireland’s Fourth National Climate Stakeholder Forum, the sustainability skills identified by the National Skills Bulletin 2023, how sustainability is a priority for 90 percent of Ireland’s manufacturing industry, the Environmental Protection Authority (EPA)’s new National Air Quality Forecast, and updates from the EU and the UN, as well as the usual roundup of updates, podcasts, articles and events. Sustainability Award News! ✨🎉Congratulations to Bank of Ireland, winner of the Leinster Society’s Published Accountants Award Sustainability & ESG Reporting (Listed Entity) and to CIÉ - Córas Iompair Éireann, winner of the Sustainability & ESG Reporting (Unlisted Entity) Award! #PAA2023 ✨🎉 Emergency Business Flooding Schemes – Ireland and Northern Ireland The Minister for Enterprise, Trade and Employment, Simon Coveney, T.D. has extended two previously approved Emergency Business Flooding Schemes for small businesses, sports clubs, community, and voluntary organisations unable to secure flood insurance and affected by recent flooding in certain areas in Ireland. Due to the exceptional severity of the flooding in some areas, the Government has agreed to activate an Enhanced Emergency Business Flooding Scheme with higher levels of financial support for businesses severely affected in certain locations, as well making immediately available financial assistance by way of low-cost loans from Microfinance Ireland to small businesses that cannot get loan financing from other lenders.  Climate experts are warning that floods constitute the greatest hazard associated with global climate change. Separately, a number of support measures have been announced to help businesses in Northern Ireland impacted by recent flooding. The support measures include rates relief for flooded business premises and one-off grant payments for affected businesses. Proposals for further schemes to support the longer-term recovery of the affected towns are being considered by government departments and local government. More information on those schemes will be released in the coming weeks. Fourth National Climate Stakeholder Forum held The fourth National Climate Stakeholder Forum (NCSF) took place this week, hosted by the Minister for Environment, Climate and Communications, Eamon Ryan, T.D. The one-day workshop is a key pillar of the National Dialogue on Climate Action (NDCA), Ireland's national programme to engage, enable and empower stakeholders and citizens across society to take climate action.  Participants at the forum – among them representatives from Chartered Accountants Ireland – discussed sectoral engagement with climate action, identified where gaps in communication existed, and ways in which as many people as possible in society could be engaged in taking climate action. The output of this forum will be a roadmap for delivering the new Action Plan on Climate Communications and Engagement. ‘Sustainability Starts with a Plan’ – Enterprise Ireland Enterprise Ireland has launched a sustainability campaign, ‘Sustainability Starts with a Plan’, to build awareness across Irish business of the supports available to help them reduce carbon emissions and develop sustainability plans. The campaign, which will include an initial six-week advertising campaign across radio, print and social media, is designed to encourage take-up by businesses of the range of Enterprise Ireland supports to assist them on their sustainability journey. Supports include consultancy advice, capacity building supports and financial grants for projects that reduce carbon emissions. Local Enterprise Officers (LEO) have similar offerings for micro businesses. Further details can be found on the Enterprise Ireland website. Upskilling and reskilling essential across business and finance The National Skills Bulletin 2023 is reporting that the skills mix of Ireland’s workforce will need to evolve as industries in Ireland address issues such as sustainable sourcing, circular lifecycles, energy efficiency, and waste minimization. The report, which was launched this week, states that, “Upskilling and reskilling will be essential across the business and financial occupations in the coming years so as to successfully navigate changes resulting from digitalisation, automation and the increased focus on sustainable finance”. This is the nineteenth such report in an annual series and was prepared by the Skills and Labour Market Research Unit (SLMRU) in SOLAS on behalf of the National Skills Council. Sustainability a priority for 90 percent of Ireland’s manufacturing industry  IBEC’s 2023 Manufacturing in Ireland report has found that there is widespread participation in the manufacturing industry in sustainability (85 percent) and digitalisation (68 percent) initiatives. Commenting, Sharon Higgins, IBEC’s Executive Director, Membership and Sectors stated that “half of organisations involved in each of these expecting to save money as a result” and that “90% of companies agreed that sustainability, is a priority for their business. Given the priority attached to sustainability and impending reporting directives, 85% are introducing initiatives in the next 1-2 years that will lessen their environmental impact and address customer expectations.” EPA launches a National Air Quality Forecast The Environmental Protection Authority (EPA) has launched a national air quality forecast to provide greater information to the public regarding expected air quality in Ireland. The forecast will provide maps showing the predicted daily air quality for up to three days -"Today", “Tomorrow” and the “Day after Tomorrow”. The air quality forecast will help people plan their activities to follow public health advice, such as reducing physical activity when air pollution levels are predicted to increase and could affect their health. The forecast maps will be uploaded twice daily, once in the morning and once in the evening. The forecast and further information on air quality and the Air Quality Index for Health are available on airquality.ie. Funding opportunities in UK and Northern Ireland  Funding is being made available to eligible organisations through Small Business Research Initiative (SBRI) competitions for innovative solutions to challenges faced by the public sector in healthcare, circular economy, agriculture and more.  Under SBRI: Delivering a Net-Zero NHS for a Healthier Future, organisations can apply for funding for early-stage innovations to accelerate the development of greener innovation towards a more sustainable healthcare system.   Creative UK is accepting applications for the Creative Catalyst Challenge Fund, offering businesses an opportunity to access grant funding of up to £250,000. Supported by Innovate UK, this fund is designed to empower creative minds to channel their innovation towards addressing specific climate challenges within the industry. The focus of this grant is to support research and development that: combats waste, promotes decarbonisation or minimizes the creative industry's impact on the environment. European Commission adopts Carbon Market Report The European Commission has adopted the Carbon Market Report, which reviews the functioning of the EU’s Emissions Trading System (EU ETS) in 2022 and the first half of 2023. The EU ETS puts a cap on greenhouse gas emissions from power and energy-intensive sectors of industry and aviation operating in Europe (approx. 36 percent of all EU greenhouse gas emissions). The cap decreases every year to reduce emissions in line with the EU climate targets. The report also captures key outcomes of the 2023 EU ETS revision in the context of the European Green Deal, which aligns the system with the EU’s target of at least 55 percent emission reductions by 2030 below 1990 levels. To date, the EU ETS had helped bring down emissions from power and industry sectors to 37.3 percent below 2005 levels.  UN Climate Adaptation Gap Report publishes The United Nations Environment Programme (UNEP) has published its UNEP Adaptation Gap Report 2023, which looks at progress in planning, financing and implementing adaptation actions. The main finding for 2023 is that progress on climate adaptation is slowing when it should be accelerating to catch up with rising climate change impacts. The report also identifies seven ways to increase financing, including through domestic expenditure and international and private sector finance. Survey – Nature Based Solutions – World Research Institute Over half of global GDP - $44 trillion - relies on nature. Yet, only 17 percent of total investment in nature comes from the private sector. The World Resources Institute (WRI) is researching how businesses are deciding to finance Nature-based Solutions (NBS) in order to support their company’s efforts to increase investment in NBS and have made available this 9-minute survey for interested companies. Technical Update From our colleagues in Professional Accounting IAASB has published a set of Frequently Asked Questions on the recently proposed ISSA 5000, General Requirements for Sustainability Assurance Engagements. The FAQ addresses, among other things, double materiality and how an assurance practitioner considers an organization’s “materiality process” during a sustainability assurance engagement. EFRAG has welcomed the adoption and integration in the European Legal Framework of the 12 European Sustainability Reporting Standards (ESRS). To support their successful implementation EFRAG has launched a Q&A platform to encourage stakeholder dialogue, and announced the development of further standards for SMEs. Accountancy Europe, together with ECIAA and ecoDa, has released a publication entitled “ESG Governance: questions boards should ask to lead the sustainability transition”. It was announced that the International Sustainability Standards Board’s (ISSB) IFRS Sustainability Disclosure Standards will be incorporated into the Brazilian regulatory framework, setting out a roadmap to move from voluntary use starting in 2024 to mandatory use on 1 January 2026. The International Sustainability Standards Board has issued its ISSB Update, and the latest episode of the ISSB podcast. Accountancy Europe - Sustainability update – October 2023 (from our friends in Accountancy Europe) EC launched call for evidence to rationalise EU reporting requirements EC adopts final delegated act on adjusting SME thresholds Sector-specific ESRS postponed Council adopts EU green bond standard regulation Stakeholder Request Mechanism for EU Taxonomy Council conclusions for COP 28 And more Listen Niall Fitzgerald from Chartered Accountants Ireland is featured on the Carmichael Podcast to talk about sustainability and its effects on the non-profit sector. Articles Tourism Ireland to ‘weigh’ benefits of further growth with environmental damage (Irish Times) Workers will accept lower pay at environmentally sustainable firms (Irish Times) Upcoming Events   ICAEW Climate Summit Week-long summit Virtual: 13-17 November. Climate Finance Week Ireland 2023 Week-long summit. In person and virtual: Monday, 20 November – Friday, 24 November includes: Corporate Sustainability Reporting Directive (CSRD) and Its Implications For SMEs In Supply Chains (Webinar) Thursday, 23 November, 10-11 Dee Moran - Professional Accountancy Lead, Chartered Accountants Ireland David Connolly - Senior Manager, EY Climate Change and Sustainability Services Donna Wilson - Head of ESG Transformation, AIB Elephant in the Room To mark this year’s Movember, Thrive, along with the Leinster Society, invites you to the unveiling of our Elephant sculpture as part of the mental health initiative, Elephant in the Room. In person: 29 November, 5pm, Chartered Accountant House – Reception Foyer SEAI SME Business Briefing A webinar to learn how your business can save money and energy this year. Virtual: 30 November, 10-11am Innovate UK's showcase for climate tech event in Northern Ireland Innovate UK is delivering a series of 18 'showcase for climate tech' events across the UK until September 2025. Each event focuses on a specific net zero theme or technology area. The Northern Ireland event, run in partnership with Business in the Community NI, will take place in Belfast on 6 December 2023 and will focus on digital solutions for net zero. In person: 6 December   Network for Chartered Accountants working on ESG projects Are you a Chartered Accountant working in ESG or working on ESG-related projects? Would you like an opportunity to engage with other Chartered Accountants working in this space to share insights, challenges and opportunities? Chartered Accountants Ireland now has a network to allow members working in sustainability/ESG to meet and discuss all matters of interest re ESG and accounting. 3rd or 4th Wednesday of every month Next: 22 November 2023  14.00-15.00/30 Teams If you would like to attend please email sustainability@charteredaccountants.ie   You can find information, guidance and supports to understand sustainability and meet the challenges it presents in our online Sustainability Centre.

Brexit has been with us for quite some time, yet challenges remain for businesses trading with the UK. Janette Maxwell outlines the practical considerations for Irish importers and exporters Recent CSO figures show imports from Britain to Ireland fell by 14 percent to €1.8 billion in August 2023 compared to August 2022, and exports from Ireland to Britain fell by 15 percent to €1.3 billion in August 2023 compared to August 2022. With imports and exports in decline, it’s hard not to look to Brexit and the challenges it has brought as the culprit. Here are some practicalities to consider when trading with Britain. Irish-based businesses unwilling to act as importers of record Where an Irish-based business sources goods from outside the EU, it may not be willing to take on the responsibilities associated with the importation. To secure these sales, the foreign supplier seeks an Irish VAT registration and an EU Economic Operators Registration and Identification (EORI) number to act as the importer of record on the basis the sales are subject to the incoterm, delivered duty paid. The foreign supplier is then responsible for the importation of the goods into Ireland and pays the import VAT and any customs duty arising from the importation. The subsequent sale of the goods by the foreign supplier is subject to Irish VAT, which is returned on the foreign supplier’s Irish VAT return, with the import VAT being claimed as input VAT. Subject to authorisation from the Irish Revenue, it may be possible for the foreign supplier to use postponed VAT accounting for the imports. Postponed VAT accounting for imports An Irish VAT-registered business may apply to the Irish Revenue for authorisation to use postponed accounting for imports. Where this is granted, an importer does not pay import VAT on the clearing of the goods through customs. Instead, the import VAT is included as output VAT in the Irish VAT return, with the importer claiming input VAT in the same return subject to the deductibility provisions. There is a requirement to include the customs value of the goods in the PA1 field of the VAT return and in the appropriate fields of the annual return of trading details, i.e. PA2 and PA3 or PA4. EORI numbers A business acting as the declarant when importing or exporting goods from the EU must have an  EORI number, enabling the EU Customs administrations to deal with customs-related procedures. An Irish-established business can obtain its EORI by applying to the Irish Revenue. However, a non-EU established business should request its EORI from the EU member state in which it first lodges a customs declaration or applies for a customs decision. Contracts that would result in a UK VAT registration obligation Should the Irish business sell goods on delivered duty paid (DDP) terms to a customer in Britain, the Irish business would have to deal with the importation of goods into Britain. Where DDP terms apply, the Irish business must appoint a UK-established agent and obtain a British EORI number. The Irish company would also have to register for UK VAT to pay over the UK import VAT arising and to charge UK VAT on the domestic supply of the goods to the customers in Britain. Postponing the UK import VAT Import VAT is typically payable at the point of importation into Britain. UK import VAT is liable on goods at the same rate which would apply to the goods had the supply occurred in the UK – i.e. 20 percent.   Like Ireland, the UK government introduced a measure allowing importers to operate a postponed method of accounting for the UK VAT. This means that the payment of import VAT can be delayed until the next VAT return following the date of importation. The Irish business would self-account for import UK VAT and – subject to the standard VAT recovery rules in the UK and its VAT recovery entitlement – would be entitled to claim a corresponding VAT deduction, potentially providing a cash-neutral position for the Irish business. It is important to remember that customs duty may also arise, which is non-recoverable and represents an absolute cost for the business. What’s ahead At the contract negotiation stage, it is vital that the Irish business understands the impact of the commercial terms to which they are agreeing and, if possible, negotiates more favourable terms which may avoid a UK VAT registration and the associated registration and compliance responsibilities. It is also essential to keep up to date with VAT legislative developments in the UK and seek UK VAT advice as required, in addition to Irish VAT advice. Janette Maxwell is a Director of Tax with Grant Thornton Ireland

The Economic Crime (Transparency and Enforcement) Act 2022 created the Register of Overseas Entities (ROE). It requires overseas entities owning UK property to reveal their beneficial owners and to register their entities on a publicly available register.  Information must be verified before an overseas entity makes an application for registration, complies with the updating duty or makes an application for removal. The Register of Overseas Entities (Verification and Provision of Information ) Regulations 2022 (SI 2022/725) set out the details of the verification system. The drafting of the Verification Regulations means that there is a strict liability in place and the accountancy professional body supervisors are concerned that any firm acting as a verifier will face significant challenges and expose itself to significant risk, including possible criminal prosecution, regulatory sanction, and reputational damage. Firms should carefully consider whether they should provide this verification work. The work required for verification under the ROE is not the same as the risk-based approach to client due diligence under Money Laundering Regulations 2017 and firms should familiarise themselves with the differences. The Government has produced further Guidance to assist. The Accountancy AML Supervisors Group (AASG) published an AML Alert highlighting key risks associated with this work. The Institute has previously shared this AASG AML Alert on ROE-Verification work with the MLCPs and MLROs but would highlight again the risks associated with this verification work.

In Irish news this week, Revenue publishes a summary of useful tips ahead of the upcoming income tax filing deadline and the October Exchequer figures show a further decline in corporation tax revenues. In UK news, HMRC has confirmed that the date from which it will no longer accept paper VAT registrations, except in limited cases, is next Monday, 13 November 2023 and in our miscellaneous updates this week, read about HMRC writing to agents in respect of potential discrepancies in 2021/22 self-assessment returns. In International news, the OECD is hosting a virtual event to mark Tax Certainty Day 2023. Ireland Revenue has published ROS Pay and File tips in advance of the personal tax extended deadline of Wednesday 15 November 2023. October Exchequer figures show a further decline in corporation tax revenues. UK HMRC has confirmed that it will no longer accept paper VAT registrations, except in limited cases, from next Monday, 13 November 2023. HMRC is writing to agents in respect of potential discrepancies in 2021/22 self-assessment returns. International The OECD is hosting a virtual event to mark Tax Certainty Day 2023. 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 EU exit corner here.      

Elephant in the Room – A Movember Event Join us for an unforgettable evening as we unveil our new Elephant in the Room sculpture to mark this year’s Movember. Venue Details:  Reception, Chartered Accountants House, 47-49 Pearse Street, Dublin 2 Start Time: Wednesday 29 November @ 5.00pm End Time: Wednesday 29 November @ 7.00pm Book Here Details: To mark this year’s Movember, the Thrive Wellbeing Hub, along with the Leinster Society, invites you to the unveiling of our Elephant sculpture as part of the mental health initiative, Elephant in the Room.  Join us for an informal evening of refreshments, conversation on men’s mental health, networking opportunities, prize draws and to meet the newest addition to the Institute – our elephant. This elephant is a declaration of our commitment to supporting members, students and employees' mental health and wellbeing and is designed to destigmatise and normalise conversations around mental health in the professional and accountancy industry. We will be joined by Elephant in the Room founder, rugby analyst, and men’s mental health advocate Brent Pope, local artist Kuse who designed our elephant, and Institute figures like President, Sinead Donovan and CEO, Barry Dempsey.  Kick off the festive season in style with opportunities to connect and network and be in with a chance to win some amazing prizes.   Draw Details: This draw is open to everyone, whether you can attend on the night or not. To enter our draw, please make a donation, small or large, to CA Support via our iDonate page and your name will be automatically entered into the draw. Winners will be contacted separately after the event.  iDonate: https://bit.ly/CASiDonate

The OECD has published the latest edition of Revenue Statistics in Africa. The publication pulls together tax revenue and non-tax revenue statistics from 33 African countries. The report enables comparison not only between the countries covered in the report, but also with the OECD and other regions.

The African Tax Administration Forum (ATAF) and the OECD have renewed their commitments to promote fair and efficient tax administration in Africa. The cooperation between these organisations amplifies African voices allowing delegates to shed light on the unique challenges and perspectives of the African continent.

The OECD is hosting a virtual event to promote tax certainty. Tax certainty is a priority of the OECD as It promotes investment, jobs and growth. You can sign up for the event until 9 November 2023.

Read our update on key developments in this area since June 2022. HMRC has also made several administrative changes to the Double Taxation Treaty Passport Scheme (“DTTPS”) which is widely used by overseas lenders to ensure UK withholding tax is deducted at the correct rate under the relevant double taxation treaty.  The tax treaties and related documents between the UK and the following countries have been updated:- Czech Republic; Slovak Republic; Cyprus; Chile; Kyrgyzstan; Guernsey; Germany; Luxembourg; India; Isle of Man; Ukraine; and San Marino. Other specific developments of note are set out below:- Use updated form DTTP1 to apply for or renew a Double Taxation Treaty passport; A new UK-Luxembourg Double Tax Treaty was signed in June 2022 and has not yet entered into force; In June 2022, HMRC published a policy paper setting out its change of view on the interpretation of the residence articles in 16 double taxation agreements; Use updated form Canada/Individual to apply for relief at source or claim a repayment of UK Income Tax; Use updated form US-Individual 2002 to apply for relief at source or to claim repayment of UK Income Tax; The UK and Brazil signed a Double Taxation Agreement in November 2022 which has not yet entered into force; and Use updated form DTTP2 to tell HMRC about a 'passported' loan. Changes to the Double Taxation Treaty Passport Scheme (“DTTPS”) HMRC has updated the contact details (both postal and email) for the DTTPS. A number of changes have also been made to the scheme’s terms, conditions and guidance document. HMRC is no longer be reminding passport holders that a passport is due to expire. Previously HMRC guidance  set out that HMRC would write to existing passport holders three months before the passport was due to expire to request completion of a DTTP1 renewal application form. From 20 October 2023 the guidance was updated and now says that HMRC does not issue reminders when a treaty passport is due to expire. The following guidance has therefore been updated accordingly:- Claiming Double Taxation Relief for companies and other concerns; and Double Taxation Treaty Passport Scheme: terms, conditions and guidance.

In this week’s EU exit corner, we bring you the latest guidance updates and publications relevant to EU exit. The latest Trader Support Service bulletin is also available in addition to the most recent Cabinet Office Borders bulletin which has returned from a break. The Minister of State has also written to the Chair of the House of Lords Protocol Sub-Committee providing an update the on the implementation of the Windsor Framework. Miscellaneous updated guidance etc. The following updated guidance, and publications relevant to EU exit are available:- Authorised Consignee Temporary Storage (ACTS) location codes for Data Element 5/23 of the Customs Declaration Service; Remote internal temporary storage facilities codes for Data Element 5/23 of the Customs Declaration Service; Importing bananas you have to pay duty on into the UK; Authorisation type codes for Data Element 3/39 of the Customs Declaration Service; Additional Information (AI) Statement Codes for Data Element 2/2 of the Customs Declaration Service (CDS); Upload documents and get messages for the Customs Declaration Service; Customs Declaration Completion Requirements for The Northern Ireland Protocol; Internal temporary storage facilities (ITSFs) codes for Data Element 5/23 of the Customs Declaration Service; Transit newsletters — HMRC updates; Locations which need a pre-lodged declaration; List of ports using the Goods Vehicle Movement Service; and EM on Windsor Framework customs arrangements.

This week we bring you news about HMRC letters to agents about a potential discrepancy on 2021/22 self-assessment returns, and HMRC has moved the Check Employment Status for Tax tool on to a new platform. The guidance on how remove a taxpayer from the self-assessment regime has been enhanced with two new videos and it is now possible to apply online to join the VAT flat rate scheme. The latest News and Information Bulletin from HMRC is also available which includes a reminder about the planned outages from 6-9 November because of IT upgrades, which we told you about last week. Potential 2021/22 self-assessment discrepancies project We are aware that from early October 2023, HMRC began sending letters to agents about potential discrepancies between their clients 2021/22 self-assessment return when compared to the P11D and P14 forms submitted by employers or child benefit information held by HMRC. The letter does not mention specific clients but advise the agent that HMRC will be in touch within three weeks (unless the agent contacts HMRC first) to share details of the clients where there are potential discrepancies.  According to the letter, if there are any discrepancies, as long as an amendment is made by 31 January 2024, HMRC will not charge a penalty. However, if no voluntary amendment is made by then, HMRC will review and consider making a discovery assessment and charging a penalty. Where an amendment results in an underpayment of tax, interest will apply from the original due date. A late payment penalty may also be payable. HMRC’s aim is to resolve these cases in advance of the 31 January 2024 online filing deadline for 2022/23 self-assessment returns. Check Employment Status for Tax HMRC recently moved its Check Employment Status for Tax (“CEST”) tool to a new platform. The move has not resulted in any changes to the questions asked however users of the tool can now review the answers to their questions after each section. In addition, guidance from HMRC’s employment status manual is now embedded in CEST. Removing a taxpayer from self-assessment HMRC has recently launched two new YouTube videos explaining the online process for taxpayers to stop self-assessment:- How to go online and stop self assessment if you're self employed; and How to go online and stop self assessment if you're not self employed. If a taxpayer believes they no longer need to complete a self-assessment return for 2022/23, it is important that they take action before the 2022/23 online filing deadline of 31 January 2024 in order to avoid being charged a penalty. Apply online to join VAT flat rate scheme HMRC recently launched a new online form which should be used by businesses to apply to join the VAT flat rate scheme (a scheme that simplifies VAT accounting for businesses with an annual turnover of no more than £150,000). Applications can still be made by post.

We recently advised that from mid-November 2023, HMRC will no longer be providing paper VAT1 registration forms on GOV.UK. This will only be available on request from the VAT helpline in exemption cases and certain limited scenarios where online registration is not currently possible. Businesses who are exempt from applying online will still be able to apply by post using a paper VAT1 form. Essentially the exemption from applying online mirrors that available under Making Tax Digital for VAT. HMRC has now confirmed that Monday 13 November 2023 is the date from which VAT registration applications must be made online in the majority of scenarios using the VAT registration service (“VRS”). It has been confirmed that those who cannot apply online are not required to apply for an exemption in advance. However, when calling the VAT helpline, HMRC will ask why a paper VAT registration form is being requested.  It should also be noted that there are several specific types of VAT registration that cannot use the VRS which includes entities (except for UK partnerships or non-established taxable persons) without a unique taxpayer reference. A full list of these is not currently available. Such businesses should call the VAT helpline to request a paper VAT1 registration form. However, HMRC is aiming to add those businesses to the VRS in future, which means that the paper VAT1 form will no longer be available once online registration via the VRS is introduced.   HMRC has also confirmed that should a digitally excluded taxpayer use the services of an agent then the application should be a digital one via the VRS. Work is ongoing to update HMRC’s guidance pages to remove the downloadable VAT1 form, and direct taxpayers to the VRS digital route. This includes letting them know what evidence will be required to be provided in advance of starting an application, including ID verification requirements. At a recent Joint VAT Consultative Committee Meeting, which Chartered Accountants Ireland participates in, external stakeholders asked about the move to more digital routes and if HMRC had tested this with external users, particularly for large organisations with diverse teams over a number of offices. This was particularly raised in the context of submitting online for the first time where it may not be clear what information is going to be needed to start the online form. Forms sometimes disappear after 28 days which can be an issue in larger organisations where it may take longer than this to complete the form. It is also the case that when submitting a form online, all that an employee needs to do is enter the organisation’s email address and tax reference. However, there is no scope to confirm that the submission has been made by the authorised signatory or that the authorised signatory has authorised the submission to be made on their behalf. HMRC’s response to this is set out below. “Prior to HMRC moving to the new VAT Registration Service extensive user research was conducted over a 3-year period with a range of users including agents. The feedback from user research was that the data being requested was reasonable and would be able to be sourced within the timescales provided. HMRC introduced the ability to ‘Save and Return’ an application. This enabling the user the time to gather relevant data if required, without the need to restart their journey again.   The length of time the application remains available is 28 days from the last log in activity, so by using the Save and Return function the length of time to complete the application will extend beyond the 28 days.  On 15 June we updated Register for VAT: How to register for VAT - GOV.UK (www.gov.uk) to include more information on what is required by someone submitting an application for VAT registration. The VRS journey mirrors the VAT1 form and the VAT 1 completion guidance can be used to prepare applications ahead of logging into VRS. VRS asks for the person completing the form to declare the capacity in which they are doing so. Part of the HMRC Charter is that we trust the information being provided to us unless we have good reason not to.   At the point of registration, we will trust that the person submitting the form is an appropriate person to do so, though we do have validation and verification processes in place to inform that decision.   There is no long-standing relationship created by someone applying on behalf of someone else, to do so the appropriate authorisations would need to be completed.”