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.

Revenue is engaging with VAT registered businesses as it transitions taxpayers from the VAT Fixed Direct Debit (FDD) Scheme to a Variable Direct Debit (VDD) facility, in line with standard industry practice. As a consequence, annual VAT filers on FDD will be required to file returns on a bi-monthly basis. The FDD scheme for VAT will be removed on a phased basis from mid-2025 following the introduction of a VDD facility and as taxpayers roll off their annual VAT filing period.  Revenue is writing to VAT registered businesses currently availing of the FDD scheme advising them of its cessation. In addition, a copy of this letter will be sent to the linked Agents’ ROS Inboxes by tomorrow, Tuesday 8 April. It is important to note that taxpayers and their agents do not need to take any immediate action for now and they should continue with their monthly FDD payments. Revenue will contact taxpayers again as they approach their annual filing period end, outlining the specific actions required to transition to VDD.  

As previously advised the Institute will be responding to the following consultations and wants to hear your views: Electronic invoicing: promoting e-invoicing across UK businesses and the public sector and Reforms to Inheritance Tax agricultural property relief and business property relief: application in relation to trusts. This week is your last opportunity to email tax@charteredaccountants.ie and share your views on the inheritance tax consultation.  April 2026 changes to Inheritance Tax (IHT) reliefs - agricultural property relief (APR) and business property relief (BPR)  As many readers will be aware, at Autumn Budget 2024 the Government announced controversial reforms to two key IHT reliefs, APR and BPR, which will commence from April 2026.   In particular:  a new £1 million allowance will apply to the combined value of property that qualifies for 100 percent BPR or APR or both - after the £1 million allowance has been exhausted, relief will apply at a lower rate of 50 percent to the combined value of qualifying agricultural and business property, and the rate of BPR will be reduced from 100 percent to 50 percent in all circumstances for shares admitted to trading on a recognised stock exchange which are not ‘listed’ HMRC has launched a limited technical consultation on this issue. Note that this is not seeking views on the overall policy change but is only examining aspects of the application of the £1 million allowance for property settled into trust qualifying for 100 percent APR or BPR. As this is a technical consultation, it is running for a shorter period of time to Wednesday 23 April 2025.  The Institute is aware of the damaging impact that these reforms will have on businesses and farms in Northern Ireland and in November 2024 flagged these concerns to the Government. We would encourage members to take the opportunity to respond to this limited technical consultation and express their wider views on this damaging policy change. You can respond by using the online form or by email to aprbpr.consult@hmrc.gov.uk.  The Institute again encourages you to share your views on these policy changes as we will again be writing to the Government to highlight the particular damage these changes will cause in Northern Ireland. Please email tax@charteredaccountants.ie by Friday 11 April 2025 with your views.  Electronic invoicing  The purpose of this consultation is to gather views on standardising electronic invoicing (e-invoicing) and how to increase adoption of e-invoicing across UK businesses and the public sector. The consultation explores how different e-invoicing approaches may align with businesses and aims to support the development of a UK approach. The consultation will run to 7 May 2025. Please share your views with us by Friday 18 April 2025.  Should you wish to respond individually, responses are being accepted by submitting a form or by email to einvoicingconsultation@hmrc.gov.uk.   

The Department of Finance has issued a paper Green Budgeting in Ireland from a Tax Perspective-update to the Methodology which outlines a methodology update to the Government’s green budgeting analysis from a tax perspective. According to this paper, the analysis undertaken shows that the tax system in Ireland as a whole can be seen as climate positive in monetary terms and that recent budgetary changes have improved the climate positive contribution of the tax system. Green budgeting is the process of documenting the impact of budgetary measures and wider fiscal policy on the transition to an environmentally sustainable and climate friendly economy. Green budgeting provides a policy framework which has the potential to induce policy changes that will result in improved environmental outcomes. The paper outlines that one of the key reasons for undertaking green budgeting in the Department of Finance is to raise awareness and understanding of how taxation is linked to climate and environmental objectives and policies.

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).  

Revenue has published its Protected Disclosures Annual Report for 2024 which provides information on both internal and external protected disclosures received in 2024. The report notes a significant increase in the number of disclosures, regarding potential tax or duty non-compliance, received by Revenue through its external reporting channels. Revenue has internal reporting channels and procedures in place for both current and former staff who wish to make a protected disclosure. In 2024, five reports were considered under Revenue’s policy on protected disclosure reporting. One report was closed following a comprehensive assessment by the Protected Disclosures Group which determined that there was no evidence of a relevant wrongdoing. Assessments of the other four reports, all received in Q4, were on-going on 31 December 2024. External protected disclosures are reports made by workers who are employed by a business, individual or organisation, other than Revenue, that contain information about potential wrongdoing related to tax, duty or customs controls. In 2024, a total of 930 reports were received through Revenue’s external protected disclosures channels with 171 reports assessed as meeting the criteria to be considered as a protected disclosure. The majority of the remainder of the reports related to reports of tax evasion not encountered in a work-related setting and this information was referred to the relevant Revenue Division for appropriate action. Compliance interventions opened on foot of the receipt of information in a protected disclosure report yielded over €1.2 million in additional taxes and/or duties for the Exchequer in 2024. Commenting on today’s publication, Revenue’s Director of Internal Audit, Leeann Kennedy said: “Revenue welcomes all reports of information regarding suspected tax non-compliance or tax evasion. Workers who provide information to Revenue under the framework of the Protected Disclosures Act are afforded a range of important legal protections. Revenue will always safeguard the worker’s identity”.

Revenue has updated the its guidance on the provision of staff awards to include a new table which summarises the tax treatment of certain staff awards. The summary table outlines the circumstances when certain award types are non-taxable. The award types listed in the summary table include staff suggestion schemes, long service, special increments and exceptional performance awards. Examination and course related awards are also mentioned.

Revenue has recently updated three other Tax and Duty Manuals. The updated manuals relate to remote working, expenditure on approved buildings and gardens and local property tax direct debits. Details are set out below. The guidance on Expenditure on Approved Buildings and Gardens has been updated to outline the process for applying via myEnquiries for a determination by Revenue allowing reasonable public access to the building or garden. The Tax and Duty manual Remote Working Relief has been updated to remove reference to  2020 as this year of assessment is now outside the timeframe for making a claim. The updated Tax and Duty manual Local Property Tax Direct Debit Guidelines provides further clarity in the overview section on valuation dates and the reference to cheque as a payment option has been removed.

On 31 March 2025, the OECD/G20 Inclusive Framework on BEPS, updated its central record of legislation with transitional qualified status to include two new qualifying jurisdictions, Guernsey and Spain. The central record includes details of the jurisdictions whose local implementation of the Pillar Two global minimum tax rules has been assessed as “qualified”.

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

Organisations must reimagine their approach to data protection, mitigating risk and adapting to new regulations in a fast-changing environment. David O’Sullivan explains why As we enter the second quarter of 2025, the data privacy landscape is on the cusp of transformative change. Rather than reacting to headlines, organisations are now compelled to reimagine their approach to data protection, blending strategic foresight with a renewed commitment to ethical stewardship. Here, we outline our top 10 data privacy predictions for the remainder of the year, pinpoint in the key trends that will shape how organisations handle compliance, mitigate risks and adapt to regulatory changes. 1. Changing DPO role in AI governance As artificial intelligence (AI) relies heavily on quality data, data protection officers (DPOs) are crucial in helping organisations understand and use their data effectively. Given the overlap between data protection and AI governance, DPOs are increasingly managing AI compliance and governance. Both roles require the ability to coordinate cross-functional teams and adapt to evolving challenges. 2. Privacy by design and privacy-enhancing technologies  With the growing need for data in AI, protecting that data and transforming it into privacy-enhancing or anonymised formats is becoming ever more essential. These tools enable organisations to benefit from their data while maintaining privacy. Privacy by design is a principle-based approach that is set to become increasingly popular, prompting organisations to review their processing activities in depth, reducing risk and improving compliance management. 3. GDPR compliance frameworks Europe's digital regulations are complex and extensive. Privacy frameworks derived from the General Data Protection Regulation (GDPR) provide a solid foundation for building comprehensive compliance frameworks. These frameworks will be updated to accommodate new compliance requirements. 4. Shifting attitudes toward compliance We saw numerous headlines about data-related fines cropping up in 2024. Regulatory bodies, such as the Data Protection Commission, have intensified their efforts to manage complaints and breaches, putting more pressure on organisations. As consumer awareness grows, driven by global discussions on data privacy, we can expect to see more attention to data protection compliance. 5. International transfers under scrutiny International discussions will lead to greater scrutiny of data transfers. Recent findings by the Court of Justice of the European Union could significantly impact international data transfers, prompting organisations to reassess their practices. 6. Consumer awareness of data subject rights In Ireland, damages have already been awarded for GDPR non-compliance. While this hasn't yet led to a surge in claims, increased awareness will empower data subjects to hold controllers accountable. Organisations may shift their focus from regulators to data subjects. 7. Increase in cookie consent enforcement Cookies, often invasive and disruptive, are under scrutiny. The Data Protection Commission’s review of cookie compliance five years ago highlighted widespread non-compliance. Combined with the European Data Protection Board’s (EDPB) Cookie Banner Task Force and increased action by groups such as the European Centre for Digital Rights, we can expect enforcement actions to ramp up as organisations have now had time to implement recommendations.  8. Proactive approach to processor compliance As privacy programmes mature, organisations will focus on the entire data lifecycle, including third-party processors. The EDPB's opinion on data processors and sub-processors highlights the importance of controllers to ensure compliance throughout the data value chain. This will likely lead to more queries and demands from controllers to processors. 9. Board assurance on data protection With GDPR in effect for seven years, boards are increasingly concerned about data protection risks that extend beyond compliance, driving demand for assurance through audits and certifications, which are rapidly maturing.  10. Greater focus on transparency To empower data subjects, organisations must provide clear and practical transparency notices. Moving away from legalistic, lengthy and obscure notices to more informative ones will enhance transparency and build trust with data subjects. David O’Sullivan is Director of Privacy, Digital Trust and Artificial Intelligence Governance at Forvis Mazars

BlackRock’s 2025 Ireland Read on Retirement survey reveals Irish workers’ retirement anxieties. With auto-enrolment imminent, increased pension awareness is crucial, writes Tim Hodgson BlackRock’s 2025 Ireland Read on Retirement survey offers a revealing snapshot of the retirement landscape for Irish workers. The research exposes significant gaps between the recognized importance of pensions and the actual confidence workers have in achieving a comfortable retirement. Despite 81 percent of respondents acknowledging that pensions are the most effective means of securing a reasonable standard of living, just 41 percent feel they are on track to achieve this goal. The disconnect highlights the urgent need for enhanced financial planning and greater awareness of retirement savings. The survey identified a palpable sense of uncertainty among pre-retirees, aged 60–69, with more than a third uncertain whether their current trajectory will be sufficient to secure a comfortable retirement. This reality reflects broader anxieties within the workforce. It is evident that, while pensions are universally accepted as crucial, tangible readiness varies dramatically among workers, particularly between those with and without Defined Contribution (DC) workplace pensions. Workers lacking a DC pension express significantly less confidence in their retirement preparedness—just 26 percent of those without one feel on track, compared to 59 percent of their counterparts who enjoy the benefits of such schemes. Jumpstarting retirement savings As Ireland prepares for the introduction of the Auto-Enrolment Retirement Savings Scheme, called My Future Fund, the survey’s findings assume even greater significance. Scheduled to roll out in September 2025, this initiative aims to integrate as many as 800,000 Irish workers into an occupational pension scheme, jumpstarting retirement savings for many who have been without work or a private pension. The upcoming scheme is viewed as a watershed moment, a once-in-a-generation opportunity to redefine how retirement savings are approached. More than two-thirds of survey participants indicated a willingness to opt into the scheme during its inaugural year, reflecting optimism about the potential of auto-enrolment to reverse current trends. However, the survey also revealed that only half of workers believe that an employee contribution rate of 4.5 percent is affordable, highlighting significant challenges that remain in the broader context of financial readiness. Generational divide Generational differences further complicate the picture. The survey found that saving for retirement ranks among the top three financial priorities for Pre-Retirees and Gen Xers. In contrast, Millennials treat it as the least pressing concern, placing it last among six financial priorities. This divergence suggests that while older generations are grappling with the immediate need to shore up retirement funds, younger workers may be postponing or deprioritising savings amid other financial demands. Additionally, 43 percent of overall respondents admitted that they should be saving more, and 32 percent felt they had started too late. A similar proportion expressed concern that state pension provisions might fall short once they retire. The research highlights that nearly nine in ten pre-retirees and Gen Xers lack a clear strategy to manage their pension pots upon retirement. A striking majority believe that pension schemes should prioritise guidance to help savers manage the transition from accumulation to decumulation. In essence, while saving for retirement remains a top priority for many, there is an urgent need for enhanced financial education and personalised solutions designed to ease the transition from saving during working years to drawing down those funds in later life. Retirement unease Overall, the insights provided by the Ireland Read on Retirement survey reflect a broader international trend of retirement unease. With initiatives such as auto-enrolment on the horizon, it is imperative that policymakers, employers, and financial advisors work together to bridge the gaps in awareness and affordability. Only then can the promise of a secure and comfortable retirement become a reality for all Irish workers. Exploring these themes further reveals the critical importance of informed financial planning, and it invites renewed discussion on how best to support diverse generations in their unique retirement journeys. Tim Hodgson is Head of UK and Ireland Defined Contribution Platforms and Retirement Solutions at BlackRock