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Tax
(?)

This week’s miscellaneous updates – 2 June 2026

In this week’s detailed miscellaneous updates which you can read more about below, HMRC has published the latest Spotlight which looks at a property business scheme being marketed to landlords, and a VAT brief of relevance to the further education sector has been published.In addition to the above, readers should also note the following:The minutes of the March 2026 Employer and Payroll Group stakeholder forum, which the Institute participates in, have been published,The National Insurance Contributions (Employer Pensions Contributions) Act 2026 received Royal Assent on 29 April 2026. This legislation gives HM Treasury the power to make regulations to introduce the £2,000 cap on the National Insurance Contributions exemption for salary sacrificed pension contributions from April 2029,HMRC has published a technical note providing a summary of the new  rules for Inheritance Tax on unused pension funds which will apply to deaths on or after 6 April 2027, and finally,In a landmark case HMRC has lost is argument in the Professional Game Match Officials Ltd (PGMOL) case. Last month’s judgment ruled in favour of PGMOL when it held that the contracts of football referees officiating matches in the English Football League were contracts for services and not contracts of employment, and as a result that the referees were self-employed.Latest Spotlight shines light on property schemesHMRC’s latest Spotlight, number 63a, has been published to warn landlords against using a scheme, sometimes referred to as a hybrid business model, which is being marketed as a way to structure a property business in order to reduce tax. Effectively, the model claims to:bypass mortgage interest relief restrictions, thereby falsely allowing increased deductions for mortgage interest for residential properties, andreduce the amount of tax payable on profits from their property businessHMRC’s view is that the scheme does not work. The Spotlight therefore warns landlords who use these arrangements that they could end up paying more tax than they tried to avoid, along with interest, penalties and high fees.The Spotlight explains in detail: how the scheme is intended to work;why HMRC believes that it does not produce the intended tax savings, and what actions taxpayers who have used the scheme should take. HMRC VAT brief for further education institutions HMRC has published Revenue and Customs Brief 3 (2026) following the Court of Appeal  (CoA) decision ‘HMRC v Colchester Institute Corporation [2026] EWCA Civ 363’. In this case, the CoA upheld the decision of the Upper Tribunal that monies received by a further education institution were third party consideration paid by the funding agencies for the supply of education to students. HMRC historically took the view that monies received by these institutions from government funding agencies was a grant and therefore the activity it funded was outside the scope of the VAT system. However, Colchester Institute Corporation successfully argued that the monies represented third party consideration paid by the funding agencies for the supply of education to students.HMRC is not appealing this decision and will consider the decision in consultation with stakeholders. It will announce any policy change in a future brief. HMRC also explains the position for taxpayers who followed the guidance in Revenue and Customs Brief 08/21.  

Jun 02, 2026
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Tax
(?)

2025/26 expenses and benefits and employment related securities deadlines

The deadlines for filing 2025/26 expenses and benefits returns and employment related securities returns are both next month on Monday 6 July 2026. The 2025/26 online filing deadline to apply for a PAYE settlement agreement is Sunday 6 July 2026, with payments due by 22 October 2026 (19 October 2026 if not paying electronically). Here’s a reminder of the key deadlines next month: 6 July 2026: deadline for submitting all 2025/26 P11D(b) and P11D forms (if benefits in kind (BiKs) not processed via payroll) and the employee must receive their copy of the P11D, 6 July 2026: deadline for online reporting of 2025/26 annual returns in respect of employment related securities,19 July 2026: deadline for non-electronic payment of Class 1A National Insurance Contributions (NIC) for 2025/26, and 22 July 2026: deadline for electronic payment of Class 1A NIC for 2025/26. Readers are reminded that from April 2027, mandatory payrolling of most  BiKs and expenses, means that income tax and Class 1A NICs will need to be reported through Real Time Information (RTI) and paid in real time.

Jun 02, 2026
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Tax
(?)

HMRC publishes updated Mandatory Tax Adviser Registration guidance for overseas advisers

We remind readers that Mandatory Tax Adviser Registration commenced last month from 18 May 2026. HMRC has now published updated guidance to help overseas advisers assess their obligations under this legislation which will be of particular interest to our members in Ireland and overseas who may also be required to register for an agent services account. For both overseas and UK based advisers, the first three-month MTAR window may have commenced from 18 May 2026, unless a later start date applies. HMRC has also published a new MTAR manual.After MTAR launched last month, HMRC began hosting weekly stakeholder drop-in sessions for trusted stakeholders, including Chartered Accountants Ireland. The purpose of these sessions is to establish a regular forum to:share feedback on the new service and user experience,highlight any early operational or technical issues, andraise questions or concerns as they arise.HMRC expects these sessions to support early identification and resolution of issues, and to ensure stakeholder insight is captured as the service embeds. These sessions are attended by HMRC representatives from the policy, project delivery, and IT teams responsible for delivering MTAR. Chartered Accountants Ireland therefore encourages members to share their feedback on MTAR with us so that this can then be discussed with HMRC at these sessions.In addition to HMRC’s guidance pages which we have previously shared, HMRC has published a range of additional MTAR resources. An interactive guidance tool is also available in addition to a useful factsheet covering common questions, including: The transition period,The scope of the registration requirement, andThose within businesses (known as relevant individuals) that need to meet the registration conditions.As a reminder, HMRC is introducing the requirement to register in stages. The current timetable to register is as follows:18 May to 18 August 2026New tax advisers, including overseas advisers who do not currently have an Agent Services Account (ASA), or online Self-Assessment or Corporation Tax account. 18 August to 18 November 2026Tax advisers who have an online Self-Assessment or Corporation Tax account, but no ASA. 18 November 2026 to 18 February 2027Tax advisers who solely provide payroll services and who do not have an ASA. 31 December 2026 to 31 March 2027 Financial services organisations with no ASA (a full definition for this group will be set out in secondary legislation).  Tax adviser businesses have three months from the start of their registration window to apply. During this period, and whilst their application is being considered, they can continue to interact with HMRC on behalf of their clients.Those with an existing ASA do not have to register again with HMRC. HMRC will contact these businesses between January and March 2027 so that checks can be conducted against the new registration requirements. To assist members with meeting their obligations under this legislation, the Institute’s MTAR hub contains a suite of resources to help you determine if you are in scope, when you need to register, and what actions you need to take. Further resources on the various sanctions available to HMRC under this legislation will be added to the hub in the coming months.

Jun 02, 2026
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Tax International
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European Commission affirms Cyprus income inclusion rule under Pillar Two

The European Commission has published a new Frequently Asked Question (FAQ) resource which affirms that all EU Member States must treat Cyprus as having a qualified income inclusion rule under the EU Pillar Two Directive. 

Jun 02, 2026
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OECD blog considers when working remotely across borders creates a taxable presence

The OECD has published a blog that explores how OECD guidance and the OECD Model Tax Convention help businesses navigate taxable presence and apply international tax rules in a changing, digitalised economy. 

Jun 02, 2026
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Tax International
(?)

OECD Consolidated Commentary on Pillar Two now incorporates Agreed Administrative Guidance

The OECD has published a Consolidated Commentary to the Global Anti-Base Erosion (GloBE) Rules. This commentary now incorporates the various tranches of Agreed Administrative Guidance published by the Inclusive Framework from March 2022 to January 2026. 

Jun 02, 2026
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Tax International
(?)

OECD report identifies how tax policy can support the wider business environment

The OECD has published a report exploring how tax policy can support a more dynamic and competitive business environment. The report stems from the decline in business dynamism, which is the process by which firms enter, expand, contract, and exit markets. 

Jun 02, 2026
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Tax RoI
(?)

Updated guidance on carbon tax relief published

The updated guidance on Natural Gas Carbon Tax Horticultural Production and Mushroom Cultivation Relief reflects the deferral of the natural gas carbon tax rate increase from 1 May 2026 to 14 October 2026.

Jun 02, 2026
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Tax RoI
(?)

Encashment options – Revenue updates pension manuals

Revenue has updated its pension manual on the encashment option for individuals with both public and private sector pensions to reflect the revised Standard Fund Threshold effective from 1 January 2026, as provided for by Finance Act 2024. The imputed distributions manual has also been updated to remove references to Approved Minimum Retirement Funds, which were abolished by Finance Act 2021.

Jun 02, 2026
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Tax RoI
(?)

New customs rules for online shopping outside the EU

Last week Revenue issued a press release announcing changes to EU customs rules for low-value imports (€150 or less) from non‑EU countries, including Great Britain. From 1 July 2026, a €3 customs duty will apply per item within a parcel, increasing the cost of many online purchases and impacting the returns process. Currently, there is no customs duty on low value imports.The €3 customs duty may be applied at checkout or upon delivery, depending on the retailer. Consumers should check sellers’ terms in advance to avoid unexpected charges or delays and be aware that goods may be shipped from outside the EU, even where a website appears Irish or EU‑based. In general, customs duty is non-refundable and if a customer decides to return an item, it is likely that the €3 customs duty will only be refundable in cases where the goods are faulty. Further information and examples, including details on how the charge is applied per item is included on Revenue’s website.

Jun 02, 2026
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Tax RoI
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Guidance on PAYE ‘Week 53’ review updated

Revenue has updated the examples in the guidance on PAYE reviews where week 53 applies to reflect the 2025 tax credits and cut off points.

Jun 02, 2026
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Tax RoI
(?)

Filing Pillar Two returns – Revenue publishes further guidance to assist taxpayers and agents

Revenue has published two new guidance manuals providing filing information relating to several Pillar Two tax returns. The new guidance on Top-up tax information return and notification of filer provides a user guide for entities required to file a Top-up tax Information Return (TIR). The TIR has been available for filing since the end of April this year. The guidance titled IIR, UTPR and QDTT Returns and Payments provides guidance on the filing and payment obligations and processes for IIR (Income Inclusion Rule), UTPR (Undertaxed Profit Rule) and QDTT (Qualified Domestic Top-up Tax) returns.The Top-up tax information return and notification of filer manual provides guidance on how to file a TIR or a Notification of Filer which is required in cases where the TIR has been filed in another jurisdiction and will be exchanged with Revenue. ROS access and upload instructions, links to the OECD’s detailed guidance and Revenue contact details are also included in the guidance.Relevant ROS access and upload instructions together with other relevant return filing and payment obligations are outlined in the guidance on IIR, UTPR and QDTT Returns and Payments.Prior to filing a return or making a payment, it is recommended that an entity should ensure their relevant Pillar Two registration is correct and up to date. In addition, where the constituent entities of a multinational or large-scale domestic group elect to form a QDTT group or a UTPR group, the members of the group should ensure that a group filer is appointed and that group filer completes the creation of the group on ROS.

Jun 02, 2026
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