Recent comments by the CEO of America’s biggest bank suggest AGMs are losing power and relevance. David W Duffy delves into the details Annual general meetings (AGMs) are crucial in corporate governance. They are a legal necessity and provide a valuable opportunity for shareholders to speak to leaders. These days, however, criticism is surfacing in some companies that AGMs are becoming a nuisance. Activist pressure So, what exactly is turning the tide on AGMs and their perceived value? In short, the activist pressure exerted recently at some very high profile AGMs.  At Disney’s most recent AGM in early April, for example, shareholders were encouraged to vote in favour of a proposal that would see the entertainment giant pay for services for people choosing to detransition. The Disney proposition had no material impact on the company’s strategy, and JPMorgan Chase Chief Executive Jamie Dimon took issue.  According to Fortune, Dimon claimed that AGMs were falling victim to “spiralling frivolousness”, dominated by lobbyists, activists and interest groups, which bear little relation to the company’s strategic direction.  There’s no “right or wrong” for a statement like this; it is really just a measure of whether or not other corporate leaders agree.  The leaders of some companies could easily agree with Dimon, especially those at the helm of companies whose AGMs are rife with debate. In companies where AGMs are quieter – sometimes to the point of formality – leaders may not need to worry. Importantly, board members and other stakeholders must remember that anything is possible at an AGM. They could, for example: serve as a hotbed for debate; become a forum for topics considered politically charged (anything from geopolitics to religion to social issues to climate change); feature shareholder proposals put forward solely to make a point, win support or express anger; or seem like a waste of time to corporate leaders because of all the above.  None of this is a given, however. It is far more likely in bigger, global companies – household names consumers feel are so big that their impact stretches beyond their mission statement. In these scenarios, stakeholders generally want the company to take a stance on every political issue, and shareholder proposals at AGMs are part of this. Are AGMs fit for purpose? The threat of any of the above scenarios may mean that some companies’ AGMs are not fit for purpose. It depends on the goals of the people who attend. Companies can’t just get rid of AGMs, however.  AGMs are a cornerstone of business. They often serve as the one opportunity many small shareholders have to speak to the company’s leaders – and, by law, this chance must always be available.  An organisation considering changing its AGM must first examine its articles of association. These are usually where AGM rules like voting procedures and scheduling are found. Beyond this, there may be wiggle room. AGM options It is advisable that leaders and participants accept that the AGM will be active, full of differing opinions and multiple proposals that go nowhere, making it feel like a distraction. If you approach the situation with this prepared mindset, you might find it easier to register the elements of impactful processes beneath the noise.  It’s also advisable to get proactive about issues. You may be better prepared if you anticipate the problems that shareholders are likely to raise and discuss them at the executive and board levels. In the process, you could gain critical insights that shape your understanding of shareholder opinions and frame a more robust conversation. However, if an organisation still wants to change their AGM – and the articles of association allow it – boards can change things like length, the requirement for in-person attendance and the time balance between corporate leaders and shareholders. It must be noted, though, that if a board changes any of these elements, it may appear to be attempting to be creating barriers to debate and shareholders might not respond well. The bright side Many companies have seen their AGMs dominated by activist noise in recent years. While this issue can be addressed by making changes, the bottom line is that the AGM as a concept is here to stay. Organisations should view the “noise” as an invitation to develop relationship management skills and stay on top of emerging trends. These are hugely important for good corporate leaders, and a busy AGM could be the time to flex those muscles. David W Duffy is a founder of the Corporate Governance Institute

  In this week’s Sustainability/ESG bulletin, read about a public consultation on strategic risks facing Ireland, as well as a report into the readiness, risks and opportunities of the Irish Financial Services sector in the transition to a net-zero future. Also covered is ISIF’s commitment of €278 million to climate investments, the £150k grant support now available in Northern Ireland for energy efficient equipment, and the usual policy updates from Europe, articles, resources and upcoming events.    IRELAND Public consultation on strategic risks facing Ireland The Government has launched a public consultation on the "National Risk Assessment 2024 – Overview of Strategic Risks”, covering strategic risks facing Ireland over the short, medium and long term. The finalised list will span five categories: geopolitical, economic, societal, environmental, and technological risk and include areas like the future direction of the EU, inflation, infrastructure deficits, housing and demographic change.  Deadline for submissions is Friday, 17 May 2024. New low-cost Home Energy Upgrade Loan Scheme The Government has launched a new low-cost Home Energy Upgrade Loan Scheme that aims to support homeowners to invest in energy efficiency. The €500 million Scheme is the first of its kind for both Ireland and the European Investment Bank (EIB) Group. Under the scheme homeowners can borrow from €5,000 to €75,000 at significantly lower interest rates to make their homes warmer and cheaper to run. The scheme is delivered by the Strategic Banking Corporation of Ireland (SBCI) on behalf of the Department of the Environment, Climate and Communications, and supported by the Sustainable Energy Authority of Ireland (SEAI) and the EIB Group.   ISIF commits €278 million to climate investments The Ireland Strategic Investment Fund (ISIF), part of the National Treasury Management Agency (NTMA), has announced three new climate investments targeting offshore wind energy, renewable energy developers, and start-ups in energy transition. The new investments bring total ISIF commitments to climate investments to €636 million since 2021, representing 63.6 percent per cent of ISIF’s stated aim of investing €1 billion in Climate in the period 2021 to 2026. IFSCOE published The Net Zero Study 2023 The International Sustainable Finance Centre of Excellence (ISFCOE), supported by Skillnet Ireland, has published a gap analysis into the readiness, risks and opportunities of the Irish Financial Services sector in the transition to a net-zero future. The report – ‘Net Zero Study 2023’ – identifies the imperative for an agile, collaborative, and forward-thinking approach to ensure a successful transition, ultimately positioning the Irish Financial Services sector as a stalwart player in the global sustainability arena. Key findings are grouped under: Regulatory and Compliance Challenges, Data and Reporting Challenges, Reputational Challenges, Skill Development and Organisational Culture Challenges, Economic Challenges, Risks, and Opportunities and Digital Transformation. European Commission calls on Ireland to correctly transpose EU legislation on industrial emissions The European Commission has sent a reasoned opinion to Ireland for failure to address shortcomings in the transposition of the Industrial Emissions Directive, which lays down rules designed to prevent and reduce harmful industrial emissions into air, water, and land, and prevent the generation of waste. Although a letter of formal notice was sent to Ireland in February 2022, Ireland's legislation still does not correctly transpose certain requirements and definitions. Ireland now has two months to respond and take the necessary measures, or the Commission may decide to refer the case to the Court of Justice of the European Union. NORTHERN IRELAND & UK Northern Ireland grant support for energy efficient equipment Up to £150k has been made available through Invest Northern Ireland's Energy Efficiency Capital Grant (EECG) to help businesses buy and install energy efficient equipment, reduce energy costs and build resilience through efficiency. The rate of support covers the total eligible project costs and is based on company size. Examples of projects that will be considered for the grant include heating and cooling equipment, motors and drives, compressed air, lighting and onsite renewable generation. The call for applications will open at midday on Monday, 29 April 2024. Tenford NetZero Accelerator programme seeks applications Minister Andrew Muir has recently announced that the Tenfold NetZero Accelerator programme is taking applications from the UK’s technology startup and SME community. The programme aims to develop innovative methods that will help improve efficiency on-farm linked to feed management and usage, easy access to nutrient data; as well as help reduce waste during the production of dark glass bottles.  Each successful technology provider will receive £20,000 in funding from the industry partners.   EUROPE 2023 European State of the Climate Report confirms alarming trend of climate change impacts The annual European State of the Climate Report, published jointly on Earth Day 2024 by the EU Copernicus Climate Change Service and the UN World Meteorological Organisation (WMO), showcases the continued alarming trend of rising temperatures and climate change impacts across Europe. Based on scientific data and analysis, the report also highlights the impacts of climate change across Europe and our societies in 2023, in particular the economic losses due to floods and the health impacts of heat stress.  Europe is the fastest warming continent, with temperatures rising at around twice the global average rate, as underlined by the European Climate Risk Assessment. Due diligence, air pollution, packaging and Energy Charter – policy updates from Europe The European Parliament has approved new rules obliging firms to mitigate their negative impact on human rights and the environment. The new Corporate Sustainability Due Diligence Directive, agreed on with the Council, will require firms and their upstream and downstream partners to prevent, end or mitigate their adverse impact on human rights and the environment. Such impact will include slavery, child labour, labour exploitation, biodiversity loss, pollution or destruction of natural heritage. The Directive now needs to be formally endorsed by the Council, signed and published in the EU Official Journal. It will enter into force 20 days later and member states will have two years to transpose the new rules into their national laws.   The European Parliament has also given its final green light to revised rules on preventing and combating human trafficking and protecting its victims. Products made with forced labour are also to be banned from EU single market.   The EU Parliament has adopted a provisional political agreement with EU countries on new measures to improve air quality in the EU so it is no longer harmful to human health, natural ecosystems and biodiversity. The revised law aims to reduce air pollution in the EU for a clean and healthy environment for citizens, and to achieve the EU’s zero air pollution vision by 2050.   The EU Parliament has adopted new measures to make packaging more sustainable and reduce packaging waste in the EU. The regulation aims to tackle constantly growing waste, harmonise internal market rules and boost the circular economy. Separately, Parliament also adopted the directive on the so-called “right to repair” for consumers, clarifying the obligations for manufacturers to repair goods and encourage consumers to extend a product’s lifecycle through repair.   MEPs have consented to the EU withdrawing from the Energy Charter Treaty, which was established in 1994 to govern trade and investment in the energy sector. The Commission proposed a coordinated withdrawal by the EU and its member states, as it considers the Treaty to be no longer compatible with the EU’s climate goals under the European Green Deal and the Paris Agreement, predominantly due to concerns over continued fossil fuel investments. Sustainability Update from Accountancy Europe (From our friends in Accountancy Europe – sign up and subscribe) The April edition of the Accountancy Europe Sustainability Update has been published, with the following and more: EC calls upon CEAOB to develop guidelines on limited assurance EP approved sector-specific sustainability reporting standards delay EP adopts its position on Green Claims Directive ESMA seeks input on technical regulatory standards for external reviewers ISSB decides its priorities for next two years GLOBAL Monday 22 April was Earth Day. The event began in 1970 in the United States and is now marked around the world. The theme this year was ‘Planet v Plastics’ and it aimed to raise awareness of the harms of plastic pollution for human and planetary health. Find out more about Earth Day in this explainer from the: What is Earth Day, when is it and what has it achieved? Talks continued this week in Canada under the auspices of the UN Environment Programme, to develop a legally binding ‘Plastics Treaty’ by the end of 2024. Final negotiations on the treaty will take place it South Korea in December. The talks follow the historic resolution made in 2022 by 175 countries to end plastic pollution and develop a plastics treaty. According to CDP (formerly the Carbon Disclosure Project), the majority of companies are overlooking plastic-related risks, and mandatory disclosure on plastics is necessary. Certificate in Sustainability Strategy, Risk and Reporting Chartered Accountants Ireland hugely popular Certificate in Sustainability Strategy, Risk and Reporting is now accepting registrations for its next sitting, start on 8 May. Register here.  Articles Earth Day 2024 - Planet vs. Plastics (Chartered Accountants Ireland) Buyers of older homes may pay thousands more per year in mortgage repayments (Irish Times) Climate Change’s ‘Physical Risks’ Are Catching Up With Banks (Bloomberg) Deforestation in Brazil's Amazon down 40% in Q1, minister says (Reuters) Climate targets oversight group backtracks after staff revolt - Science Based Targets initiative says its guidance on carbon offsets has not changed pending draft rules in July (Financial Times) ACCA unveils five-point climate plan for accountants on Earth Day (Accountancy Today) With a landmark Global Plastics Treaty on the horizon, the time for corporate disclosure – and action – is now (Edie) A global plastics treaty is being negotiated in Ottawa this week – here’s the latest (The Conversation)   Upcoming Events  Chronos Sustainability/ UCD Michael Smurfit Graduate Business School , JCI (Junior Chamber International), Careers in Sustainable Finance Speakers will include NTMA's Emma Jane Joyce, SustainabilityWork's Laura Heuston and Chronos Sustainability's Dr Rory Sullivan In person: 29 April, UCD Smurfit School, 6.30-7.30pm   iQuest & Business Post, ESG Summit 2024  In person, Dublin (Croke Park), 30 April Chambers Ireland, Green Public Procurement - Half-day virtual workshop All companies now need to learn the green public procurement rules to bid and win new contracts with the public sector. Green Public Procurement (GPP) is a process where public authorities seek to source goods, services or works with a reduced environmental impact. The Government’s GPP Strategy and Action Plan for 2024-2027 has been published here. For some contracts with immediate effect, and from 2025 all tenders over €50,000 must include sustainable end environment technical specifications and contract specific award criteria. Virtual (Zoom), €99 for Dublin Chamber members and €330 for non-members, Wednesday 8 May, 9.00 – 13:00   Change by Degrees, CSRD is a Team Sport Webinar to give insights into the Corporate Sustainability Reporting Directive (CSRD) and discover how to equip your team for the future of sustainability regulation. Discover how your business can excel in sustainability practices and turn compliance into a competitive advantage. Virtual (LinkedIn Live), 10 May, 10.00 – 10.30am   European Commission Supporting companies in applying the European Sustainability Reporting Standards (ESRS)” In-person and virtual: 16 May , 09:00 - 13:00 CET Half-day event to showcase ongoing initiatives and discuss ideas for further mechanisms to support companies that apply the new European Sustainability Reporting Standards. ICAEW, Preparing your business for the green workforce, (time to be confirmed) This webinar will provide an overview of the latest trends on green skills in the UK economy and the key steps businesses are to take to develop an inclusive green talent pipeline. The speakers will feature case studies of UK businesses that have implemented green skills development initiatives and key recommendations. 21 May, Virtual   Department of Enterprise, Trade & Employment, Responsible Business initiatives: Rising expectations The need for businesses to operate responsibly is increasingly reflected in mandatory measures creating obligations for enterprises. This event will describe the Responsible Business landscape, and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, proposed EU regulation on prohibiting products made with forced labour from the Union market, and the proposed EU Directive on Corporate Sustainability Due Diligence Virtual, 22 May, 2.30pm National Sustainability Summit 2024 In person (RDS, Dublin), May 28-29   1Business World, 2024 Global Natural Capital Conference Virtual, June 3-4, 2024,   EPA Circular Economy Conference 2024 Online and inperson (Aviva Stadium, Dublin), 25 September.   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. Next meeting: Wednesday, 22 May, 14:00-15.30 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.

In Irish news, the Minister for Finance is encouraging taxpayers to make arrangements by 1 May to repay warehoused debt, and Revenue publishes statistics for 2024 Local Property Tax. In UK news, we issue a final reminder about the 30 April 2024 deadline for the end of the VAT margin scheme for second hand cars transported to Northern Ireland from Great Britain before 1 May 2023, and read about the tax announcements made as part of last week’s Tax Administration and Maintenance Day. In International news, a new report has been published on the future of the EU Single Market. Ireland The Minister for Finance is encouraging taxpayers to make arrangements by 1 May to repay warehoused debt. Revenue has published statistics for Local Property Tax (LPT) 2024. UK 30 April 2024 is the deadline for the end of the VAT margin scheme for second hand cars transported to Northern Ireland from Great Britain before 1 May 2023. Read about the tax announcements made in last week’s Tax Administration and Maintenance Day. International A new report has been published on the future of the EU Single Market. 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.          

The former Italian Prime Minister Enrico Letta recently launched a report on the EU Single Market. The report focuses on competitiveness, streamlining EU regulations to boost the data economy, investment in digital innovation, governance, tax, energy/climate, and SME competitiveness. There is anecdotal feedback that the document is being considered as a key document for the next EU Parliament. The Taoiseach has noted that while Ireland supports the integration of capital markets, this should not involve the harmonisation of corporate tax or insolvency laws.

Revenue has updated the Tax and Duty Manual regarding charities and sports bodies online applications for tax exemption. The guidance now reflects the increase in the value threshold requirement for audited accounts for charities, from €100,000 to €250,000 (paragraph 7.2). 

Last Thursday on Tax and Maintenance Day, the Government published a written ministerial statement setting out further detail on various commitments made at the March 2024 Spring Budget. This includes the launch of a consultation on the impact of recent High Court rulings on the VAT treatment of private hire vehicles and an update on the recent consultation on tackling non-compliance in the umbrella company market. The government also announced two further technical tax policy proposals.  In summary, the announcements were as follows:- VAT treatment of private hire vehicles – a consultation has been launched on the potential tax impact of recent High Court rulings on the private hire vehicle sector. This consultation also invites views on potential Government interventions that could help to mitigate any undue adverse effects on this sector and its passengers. The consultation is open until 8 August 2024; Tackling non-compliance in the umbrella companies market – the Government will publish a response to this consultation in due course. HMRC will publish new guidance later this year which will include an online pay checking tool. At present, the Government is considering introducing a statutory due diligence regime for businesses that use umbrella companies and will continue to engage with the recruitment industry and other key stakeholders on the detail of this;  VAT treatment of charitable donations - to encourage charitable giving, the Government will consult later this year on introducing a targeted VAT relief for low value goods donated to charities by businesses which the charities then give away free of charge to those in need; and  Mandating postcode provision for freeports and investment zones national insurance contributions (“NICs”) reliefs – a legislative change will be introduced which will require employers operating in a freeport or investment zone special tax site to provide their employee’s workplace postcode to HMRC if they are claiming the relevant secondary Class 1 NICs relief through payroll. This will be underpinned by a four-week technical consultation on the draft regulations required to implement this.  Full details of the various publications and announcements made are available at:- https://www.gov.uk/government/publications/summary-of-tax-administration-and-maintenance-spring-2024. 

The Minister for Finance, Michael McGrath TD, has welcomed data published by the Central Statistics Office (CSO) which shows a General Government Surplus of €8.3 billion last year, the equivalent of 2.9 percent of GNI*. This compares with an €8.6 billion (3.2 percent of GNI*) surplus in 2022. A record level of corporation tax receipts in 2023, just under €24 billion, is a key part of the surplus.  Previously large budgetary deficits were recorded in 2020 and 2021 as the Government provided support to households and firms during the pandemic.  Commenting on the figures, the Minister for Finance, Michael McGrath T.D. said:  “I welcome today’s figures which show the Irish government achieved a significant budgetary surplus in 2023 for the second year in a row. This result is testament to the careful management of our public finances in recent years and gives us options that are not open to many peer countries in the developed world.  It is also noteworthy that General Government Debt fell in 2023 compared to the previous year. Next week, Minister Donohoe and I will publish the Stability Programme Update (SPU) which will again project that our public finances will remain in healthy positive territory this year and in the coming years.  However, it is important not to lose sight of the fact that at least part of the surplus is due to the strength of corporation tax receipts, some of which is likely to prove windfall in nature. While our headline position is strong, this can change quickly given the inherent volatility in our corporation tax receipts and the dependence we have on revenues from a small number of multinational companies.  In this context, it is imperative that transitory revenue streams are not used to finance permanent increases in expenditure or reductions in taxation. With this in mind, Government recently published legislation providing for the establishment of the Future Ireland Fund and the Infrastructure, Climate and Nature Fund. The Bill has now passed second stage in the Dáil and will proceed to committee stage shortly.  The Future Ireland Fund will help deal with future expenditure pressures including ageing, climate, digitalisation and other fiscal and economic challenges. This is not a rainy day fund because these are costs we know are coming our way. If we don’t make provision for them now, future governments will face very difficult choices in the years to come to ensure revenues match the expenditure commitments of an ageing population. The purpose of the Future Ireland Fund is to support State expenditure from 2041 onwards in a consistent and sustainable manner.  The Infrastructure, Climate and Nature Fund will seek to deal with the historic pro-cyclicality of public spending and to assist with climate change objectives and nature, water quality and biodiversity issues. I want to ensure that no future government ever has to slash investment in critical infrastructure in areas such as housing, transport, health, education and energy, when we encounter an economic downturn or shock. The ‘stop, start’ approach to public capital investment must be consigned to history.  These two new long-term funds will make the future safer for our economy, our public finances and our people. My aim is to have the legislation enacted before the summer recess and have the Funds in place later this year.  I now look forward to the publication of the SPU next week, the National Economic Dialogue next month, and the publication of the Summer Economic Statement before the summer recess, as we work towards Budget 2025 next October.”  *Gross National Income (GNI) is an indicator designed specifically to measure the size of the Irish economy by excluding Globalisation effects. 

In recent weeks we have issued several reminders that 30 April 2024 is the deadline for the end of the VAT margin scheme in respect of second-hand vehicles moved to Northern Ireland from Great Britain prior to 1 May 2023. If these vehicles are sold after 30 April 2024, VAT will therefore be chargeable on the full selling price and not on the margin made.   Readers are also reminded that vehicles moved to Northern Ireland from GB on or after 1 May 2023 can use the new VAT related payment scheme, if certain conditions are met. However, this is not available if the vehicle was moved to Northern Ireland prior to 1 May 2023.  

Check out the latest items on the Agent Forum. Remember, in order to view each item, you must be signed up and logged in.   All agents, who are a member of a professional body, are invited to join HMRC’s Agent Forum. This dedicated Agent Forum is hosted in a private area within the HMRC’s Online Taxpayer Forum. You can interact with other agents and HMRC experts to discuss topical issues and processes. 

Revenue, in conjunction with the Department of Social Protection (DSP), is hosting in-person information sessions for people over the age of 65 in April and May. The sessions will be held in Dublin, Louth and Donegal from 29 April to 3 May 2024.   Information will be provided on Capital Acquisitions Tax (CAT), PAYE, income tax and DSP Long-term Carers Contribution. There will also be presentations from Citizen’s Information and the Law Society (Wills).  Those attending the meeting must register in advance by calling 085 8582633 or emailing Over65Outreach@revenue.ie, before 24 April if possible.  Further details are available on Revenue’s website. 

Do you use HMRC online services? Don’t be caught out by the planned downtime to some services. HMRC are warning about the non-availability of specific services on the HMRC website, a range of services are impacted. Check the relevant page for information on planned downtime. 

In this week’s EU exit corner, we bring you the latest guidance updates and publications relevant to EU exit. The most recent Trader Support Service bulletin is also available and InterTrade Ireland is hosting a series of free webinars to help businesses navigate trade between Ireland, Northern Ireland and Great Britain (“GB”). HMRC has also launched a new online service for businesses importing goods into GB and Northern Ireland and we update you on some matters discussed at a recent meeting of HMRC’s Northern Ireland Joint Customs Consultative Committee.  New online service for importers  Businesses importing goods into any part of the UK can now use a new HMRC online service for the following purposes:- view and manage your cash account (top up and withdraw funds);  set up a Direct Debit for and top up a duty deferment account;  request older statements and certificates;  view and manage your general guarantee account;  manage the email address linked to your account;  access secure messages from HMRC related to your account; and  set up, manage, or view account authorities.  You can also view and download:- duty deferment statements;  import VAT certificates (C79);  postponed import VAT statements; and  notification of adjustment statements.  In order to use the service, you must be subscribed to the Customs Declaration service (“CDS”) and can sign in to the new service using the Government Gateway user ID and password used to subscribe the CDS.  Meeting of HMRC’s Northern Ireland Joint Customs Consultative Committee (“NI JCCC”)  The Institute was in attendance at the most recent meeting of HMRC’s NI JCCC, a stakeholder forum to discuss Northern Ireland specific customs issues as a result of the UK’s departure from the EU.  At the meeting HMRC presented on the issue of consumer parcels being sent from GB to NI. A new system will be operational from Spring 2024, the UK Carrier Scheme, before the next phase of the Windsor Framework takes effect from 30 September 2024. In summary, from 30 September 2024, consumer parcels will be able to be sent from GB to NI without customs declarations. However, some information will need to be provided in bulk under the new UK Carrier scheme which aims to remove the burden from the border.  HMRC will issue further guidance and stated that they will not be auditing large movements of parcels. However, if there is a perception of potential abuse of the scheme, for example by moving goods from GB to NI for the purposes of onwards movement into the EU, HMRC will raise this with carriers. A number of upcoming milestones were also highlighted which we will provide more details on in due course.   The consultation on the introduction of the UK’s Carbon Border Adjustment Mechanism (“CBAM”) was also discussed. This will be introduced from 1 January 2027. The Government is considering minimum thresholds and plans to operate this like a domestic tax making the person who is responsible for the goods the person responsible for paying this tax, not the customs agent. This will be implemented by primary and secondary legislation and will also be followed by the development of guidance.   A question was asked if there is a liability to the EU CBAM for Northern Ireland importers if Northern Ireland importers are moving the goods into the EU, but the goods are coming from GB into Northern Ireland. HMRC confirmed that imports into Northern Ireland are not subject to the requirements of EU CBAM. Imports into the EU, including Ireland, are subject to the EU CBAM.   Miscellaneous updated guidance etc.   Recently updated guidance, and publications relevant to EU exit are set out below:-  External temporary storage facilities codes for Data Element 5/23 of the Customs Declaration Service;  Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service;  Known error workarounds for the Customs Declaration Service (CDS);  Apply for a voluntary clearance amendment (underpayment) (C2001);  Access trader testing for the New Computerised Transit System Phase 5;  Customs Importer and Exporter Population 2023; and  Customs Importer and Exporter Population.