The Economic Crime & Corporate Transparency Act (ECCTA) 2023 received Royal Assent on 26 October 2023, and the provisions of the Act are starting to be implemented. The primary aims of the ECCTA are to enhance corporate transparency and reduce economic crime, therefore providing increased benefit to the UK economy, for both businesses, and individuals. To facilitate these aims, the Act implements provisions about companies, limited partnerships and other corporate entities, including the registration of overseas entities and the individuals associated with them. As part of implementation of the Act, Companies House will have new and enhanced powers to improve the quality of the information held on the Companies Register. Companies and individuals will also be required to comply with their obligations to deliver documentation on time and in the correct format. A number of the changes are being implemented from March 2024; these are outlined below. The changes will apply to incorporated entities, limited partnerships and limited liability partnerships. It will also apply to their members and directors. Companies House has set out the following important changes:  • Appropriate registered postal and email addresses – Companies will need to ensure their registered office address is “appropriate”, meaning that any document delivered to that address would be reasonably expected to come to the attention of a person acting on behalf of the company, and acknowledgement of delivery can be provided. For these reasons, PO Boxes will no longer be permitted as registered office addresses. Companies will also need to supply an appropriate email address with their next confirmation statement. As part of the transition, we understand Companies House will communicate to companies both by post and by email, with an eventual move to email-only communication. • Lawful purpose – On incorporation, the subscribers (the members of the entity at point of incorporation) will need to make a statement that the entity is being formed for a lawful purpose. A similar statement will be required for all entities on their next confirmation statement, confirming that all intended future activities are lawful. • Greater powers for Companies House – The Registrar will have enhanced powers to scrutinise, query and reject information it believes to be incorrect or inconsistent with information already held on the Register. In some cases, the Registrar will have the power to remove previously filed information. Annotations will also be made public on the Register to make stakeholders aware of potential issues with information supplied. • Enforcement and sanctions – Companies House will be given greater power to take action where a company, and its directors, do not respond to formal requests for information, or where their registered office is not an appropriate address. Sanctions could include financial penalties, annotations on the company’s public record, or even in the most severe cases prosecution. In addition to the above, Companies House will be closing their Belfast office to the public from 4 March 2024. Therefore, filing paper documents, including financial statements and confirmation statements in person will not be possible at the Belfast office from that date. Individuals wishing to file information in paper format will need to post the documents to the Registrar’s office in Cardiff. Electronic filing options are available for almost all documents, and Companies House are encouraging companies to avail of these filing options, as they phase out paper filings. Further information on the remaining significant changes, such as the identity verification requirements and changes in filing options, will be available in the coming months from Companies House. Article written by Maeve Hunt, Principal – Head of Accounting Services Grant Thornton (NI) LLP and Chair of the Members in Practice Committee. Originally published in Practice News February 2024. The opinions expressed are solely those of the writer and not to be construed as those of the Institute. The purpose of technical articles is solely to draw the attention of the reader to issues, and these should never be construed as guidance or relied on. To the fullest extent permitted by law, no liability is accepted by the Institute or the author for persons acting or failing to act as a result of anything contained in this article.  This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.

Economic Crime and Corporate Transparency Act 2023 Just published see our short guide on the UK’s Economic Crime and Corporate Transparency Act 2023.The guide details some of the changes which will be brought about by the Act. 

The UK Money Laundering and Terrorist Financing (Amendment) Regulations 2023 (Regulation 1371/2023) which took effect on 10 January 2024, provides that for the purpose of assessing risk, the starting point is that domestic (i.e.UK) PEPs present a lower level of risk than non-domestic PEPs .If no enhanced risk factors are present, the extent of enhanced customer due diligence measures to be applied in relation to that customer or potential customer is less than the extent to be applied in the case of a non-domestic PEP. A parliamentary statement on lower risk of domestic PEPs explains the change is to ensure that relevant persons take a proportionate and risk-based approach to the treatment of domestic PEPs, and to allay concerns that a number of holders of prominent public positions and their family have encountered problems accessing financial services due to their status as Politically Exposed Persons. This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.    

The UK Government published its first sanctions strategy on 22 February 2024. The strategy addresses how it uses sanctions as a foreign and security policy tool. It sets out the continued investment, partnerships and structures that support UK government sanctions and the cross-government architecture built to deliver sanctions. It outlines the partnerships developed with the private sector, NGOs, and international partners, and the steps being taking to strengthen sanctions implementation and enforcement. This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.

The Digital Services Act 2024 (“DS Irish Act”) was passed into law on 11 February 2024 and came into force from 17 February 2024.Please click here for a DETE press release giving more details of the DS Irish Act. The EU Regulation (“Regulation”) commonly referred to as the Digital Services Act applies in full in all Member States from 17 February 2024.The Regulation establishes a pioneering regulatory framework to protect EU users of digital services and their fundamental rights online.  While the Regulation has direct legal effect in EU Member States, it was necessary to have national legislation to implement those provisions of the Regulation that provide for the supervision and enforcement of those obligations. The DS Irish Act 2024 fulfils Ireland’s obligations in this regard. The DS Irish Act formally designates and empowers Coimisiún na Meán as the Irish Digital Services Coordinator and the Competition and Consumer Protection Commission as a competent authority for online marketplaces under the Regulation. When the DS Irish Act was published as a bill late last year it was clarified at the time in a press release from DETE that it was a technical bill, drafted to address specific obligations on Member States of the EU to give effect to the supervision and enforcement provisions of the Regulation. The bill did not add to or amend the obligations on online platforms under the Regulation. Those obligations have direct legal effect in all Member States of the EU and do not require any implementing measures in national law. This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.  

The latest UK tax tidbits features guidance across a wide range of areas in addition to details of its most recent performance reports on service levels for the quarter ended December 2025. Whistleblowing: prescribed person reports, Check for signs of outsourced labour payroll fraud, Complain about HMRC online services, Help with sharing group structure information — GfC17, HMRC issue briefing: operational activity following the new independent review of the Loan Charge, Employer Bulletin: February 2026, Inheritance Tax: foreign assets (IHT417), Check the recognised overseas pension schemes notification list, Appeals reviews and tribunals guidance, Recognised stock exchanges — designated countries, Corporation Tax: return of Income Tax on company payments (CT61), Plastic Packaging Tax: steps to take, The fit and proper test, Named tax avoidance schemes, promoters, enablers and suppliers, HMRC performance updates, HMRC performance update: October to December 2025, Check genuine HMRC contact that uses more than one communication method, Work out Inheritance Tax due on gifts, Class 1A National Insurance contributions on benefits in kind (CWG5), Collect and verify digital platform seller information, HMRC introduces GOV.UK One Login for new customers, HMRC standard for agents, Check if a text message you've received from HMRC is genuine, Changes and issues affecting the Corporation Tax online service, Get help to correct an employer PAYE bill, Check when you can expect a reply from HMRC, HMRC Trusts and Estates newsletters, HMRC email updates, videos and webinars for off-payroll working, Check if a QR code on a letter you've received from HMRC is genuine, and Check if a letter you’ve received from HMRC is genuine.

In this week’s cross-border trading corner, we bring you the latest guidance updates and publications. 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. And finally, the House of Lords Northern Ireland Scrutiny Committee has published the Government’s response to its first report following its inquiry into strengthening Northern Ireland’s voice in the context of the Windsor Framework. Miscellaneous guidance updates and publications This week’s miscellaneous guidance updates and publications are as follows: Inverters with maximum power point tracking functionality (Tariff Notice 2), Remote internal temporary storage facilities codes for Data Element 5/23 of the Customs Declaration Service, Moving sheepmeat, poultry and beef to Northern Ireland from outside the UK and EU, 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, How to claim a repayment of import duty and VAT if you've overpaid, Report incorrect Customs Duty or VAT on items imported by post (BOR286), Report a problem using the Customs Declaration Service, Notice to exporters 2026/03: director jailed for illegal export, and Transit newsletters — HMRC updates.

In this week’s detailed miscellaneous updates which you can read more about below, HMRC has published the latest Agent Update and HMRC has sent an update on its Corporation Tax return and payment reminder trial. In other news this week: The UK and India have signed a social security agreement to eliminate the potential for double social security for temporary workers, The Institute for Fiscal Studies has published From fiscal rules to fiscal traffic lights: rethinking the UK fiscal framework and How to fix the fiscal rules, HMRC’s latest newsletter for participants of the 2025 Making Tax Digital for income tax testing programme is available, The latest schedule of HMRC Talking Points live and recorded webinars for tax agents are available for booking. Spaces are limited, so take a look now and save your place, and finally, Check HMRC’s online services availability page for details of planned downtime and the online services affected. Agent Update: Issue 140 Get the latest guidance from HMRC if you're a tax agent or an adviser. The latest edition of HMRC’s Agent Update features the following: • closure of the service to file company accounts and tax return, • upcoming State Pension age changes–impact for individuals and payroll, • prepare for Vaping Products Duty registration from 1‌‌‌April‌‌‌2026, • submitting your clients’‌‌‌2026‌‌‌/27‌‌‌Annual Tax on Enveloped Dwellings returns, and • get ready for Making Tax Digital for Income Tax now. Update: Corporation Tax return and payment reminder trial Since July 2025 HMRC has been conducting a trial which involves not sending Corporation Tax return and payment reminder letters (CT208 PR1 and CT208 PR2) to approximately 5 percent of companies that have an authorised agent. The trial is testing whether or not removing the CT208 will impact companies supported by an agent. HMRC has now sent an update on that trial which we share below: “As part of HMRC’s efforts to improve its services to send and receive taxpayer information digitally, HMRC is continuing its trial of not sending Corporation Tax reminder letters (CT208) where customers and agents can access the same information via online services when they need it.  From March HMRC will begin the next phase of the trial of not sending CT208 reminders to a small population of customers who are without an agent. We will monitor the effect over six months and stop the trial if we see a negative impact on our customers or process. There are no changes to the Corporation Tax process itself. Companies will still receive a notice to deliver a Company Tax Return and access their HMRC online accounts. Agents can access HMRC's Corporation Tax for Agents online service to view liabilities and payments. Information on the Company Tax returns is available on GOV.UK where there is also guidance on the Corporation Tax accounting periods.   Previous copies of communications “Agent Update – published 21 August Changes to Corporation Tax reminders, statements and receipts HMRC will stop sending some paper non-statutory Corporation Tax letters where customers can access the information in their HMRC online accounts or GOV.UK guidance. Agents can access the information in HMRC's Corporation Tax for Agents online service. The Corporation Tax process is not changing. This is part of HMRC’s wider drive to help the environment and bring down costs by reducing its use of paper to communicate with customers. From September the following Corporation Tax letters will no longer be issued: CT205/A return reminder CT608 instalment payment reminder CT207 interest statement CT209 payment receipt From October we’ll also stop sending the CT603A agent list of issued notices to deliver Company Tax return (customers will still receive the CT603 notice to file). We’ll also trial no longer sending CT208 reminders before we stop sending them permanently. The trial runs from September until January 2025. We will monitor the effect and stop the trial if we see a negative impact on our customers or process. The letters to be trialled are: CT208 PR1 payment reminder CT208 PR2 return and payment reminder CT208A PR2 return and payment reminder agent copy.” “Changes to Corporation Tax reminders, statements and receipts – sent May 2025 As part of HMRC’s continuing efforts to improve its services to send and receive taxpayer information digitally, HMRC is no longer sending paper copies of some Corporation Tax (CT) letters where customers and agents can access the same information via online services when they need it.   From June, we’ll no longer automatically send the following non-statutory Corporation Tax letters: CT205/A return reminders for companies and agents  CT207 interest statement  CT209 payment receipt  CT603A agent list of issued notices to deliver Company Tax return   CT608 instalment payment reminder  We’ll also trial no longer sending Corporation Tax reminder letters (CT208) before we stop sending them permanently. The trial will initially stop sending reminders to a small population of customers with agents and, if successful, we’ll increase this and eventually include the CT208 reminders to customers. We will monitor the effect and stop the trial if we see a negative impact on our customers or process.  There are no changes to the Corporation Tax process itself. Companies will still receive a notice to deliver a Company Tax Return. Customers can also contact us by phone or post for any queries.   Companies can also access their HMRC online accounts and agents can access HMRC's Corporation Tax for Agents online service to view liabilities and payments. Information on the Company Tax returns is available on GOV.UK where there is also guidance on the Corporation Tax accounting periods.””

Last Monday the Institute met with representatives from the Northern Ireland Chamber of Commerce and the Confederation of British Industry Northern Ireland (NI) to discuss potential ways forward in our ongoing campaign to reduce the corporation tax rate in NI. The meeting was very informative and productive with each of the organisations agreeing that NI needs a coherent, long term industrial policy that attracts investment, creates secure, well paid jobs, and fosters innovation. There was also agreement on the end goal of reducing the corporation tax rate in NI. The key issues and Institute stance Research by the ESRI in 2021 'Enhancing Attractiveness of the Island of Ireland to High-Value Foreign Direct Investment' states that a reduction in the rate of corporate tax to 15 percent would yield an annual increase of 7.5 percent in high-value foreign direct investment in NI. The need for an up to date economic assessment of the impact of reducing the corporate tax rate on employment, earnings, and investment is therefore viewed as an important step in the current campaign. One of the main issues remains the potential impact on the block grant that NI receives every year. The Institute outlined various measures that could be availed of to overcome this issue, most notably the use of a low interest loan from Westminster to manage the initial drop in corporate tax revenue that would arise immediately after the rate reduction.  Our progress to date and next steps  The meeting was an important step in achieving a united approach across the business community in NI. Work will continue to garner cross-party consensus on reducing the corporate tax rate in NI which will be critical when the campaign is taken to Westminster. This point was highlighted during the Institute's recent appearance before the joint Economy and Finance Committees in Stormont last month. As outlined previously, in November 2025, the Institute wrote specifically to the Exchequer Secretary to the Treasury on this issue. In the letter, we highlighted that the ultimate aim of a lower rate is for it to become self-funding in the longer term, but that it would necessitate a replacement loan at a low interest rate from HM Treasury to fund the necessary block grant reduction. Last year the Institute published its position paper ‘Enhancing Our Competitiveness: The case for a reduced rate of corporation tax in Northern Ireland’ which launched its refreshed campaign for a lower rate.

Last week HMRC published guidance on mandatory tax adviser registration which will officially open for registrations from 18 May 2026. The guidance sets out the timetable for registrations and information on how to check if you meet HMRC’s conditions to register. Importantly, if an agent already has an agent services account (ASA), the agent will not need to register again. HMRC will subsequently contact the agent via its ASA when it needs more information in order to check that the agent meets certain conditions. The Institute has set out below important advice on what actions tax advisers need to take to get ready for these changes. Agents who do not have an ASA and who meet the conditions to register will need to register for an ASA from 18 May 2026, unless one of the following applies: if the agent already has a Self-Assessment or Corporation Tax account, registration is required from 18 August 2026, and if the agent only provides third-party payroll services on behalf of clients and does not interact with HMRC in any other way, registration is required from 18 November 2026. However, an agent will be able to use HMRC’s new online service, which will be available in the coming months, to register from 18 May 2026, even if not required to do so until a later date. What does mandatory tax adviser registration mean? Registration will be required for any ‘tax adviser’ who interacts with HMRC in relation to the tax affairs of their clients, irrespective of where the adviser or the client is in the world or where the services are provided from. The draft legislation defines ‘tax adviser’ as an organisation or individual who, in the course of a business carried on by them, assists other persons with their tax affairs. This is then defined broadly defined to include: Providing advice in relation to tax, Acting or purporting to act as an agent on behalf of the other person in relation to tax, or Providing assistance with any document that is likely to be relied on by HMRC to determine the other person’s tax position.  Who needs to register? Registration is required at firm level. However, certain registration conditions can still apply to individual staff members within the firm and individual officers of the firm (including partners, directors, and LLP members). If a tax adviser operates a sole trade, they will need to individually register in their own name. There are limited exceptions and exemptions to the requirement to register. For example, HMRC has already confirmed that those who provide pro-bono tax advice and ‘in-house’ tax advice in their own or their employer’s business are not within the scope of the regime. How will advisers register? HMRC has been allocated £36 million to develop a new dedicated online registration system which remains in development and is not yet available. Initial registration and maintenance of a tax adviser’s registration will be free and not subject to a charge. From recent discussions with HMRC about the new system, it seems that this will involve the existing agent identifying who their relevant individuals are, which will then require those individuals to provide permission for HMRC to share their personal data with their firm if this is related to the registration conditions. The agent will then need to confirm that their firm meets the registration conditions or explain if they do not. What information needs to be provided when registering? The exact registration requirements are awaited from HMRC. However, we do know that applications for registration will need to include: The name and address of the firm, The name of each ‘relevant individual’ in the firm (essentially, those individuals with responsibility for the tax work undertaken by the firm.  However, for some firms the definition may be wider than this as there are minimum numbers of ‘relevant individuals’ who must be named), A statement that each of the three registration conditions are met, or ifthese are not, there must be an explanation why, and Any other information as HMRC may specify in a notice (we are not yet aware what this may be as no such notice has yet been published). Essentially, the number of relevant individuals to be named depends on how many ‘officers’ (company directors, partners in partnerships, and members of LLPs etc.) a firm has.  Notably, the draft legislation in the Finance Bill does not cap the number of relevant individuals at five and the legislation sets out different requirements for firms with five or fewer officers and those with six or more. What happens after a registration application is made? HMRC will consider the tax adviser’s registration application and will then decide whether or not to approve it at which point the tax adviser will be notified of their decision. If rejected, this can be appealed to an independent tribunal, after a formal internal review has been completed. If the conditions for registration are met, HMRC must approve the registration. If they are not met solely because the firm or a relevant individual has an outstanding tax return or payment, HMRC can still approve the application if they consider it to be appropriate. These decisions will be based on pre-determined thresholds and circumstances, precise details of which are awaited. At present we are also not aware of the expected timescale for HMRC to respond to registration applications, despite setting out the importance of this in our consultation submission. The registration requirement provides HMRC with a range of monitoring and enforcement powers, and sanctions and penalties which can be imposed for non-compliance. The draft legislation also contains a range of safeguards, including appeal rights. HMRC will be able to suspend a tax adviser's registration in certain circumstances, including if their behaviour does not meet ‘expected standards’ (more detail on this is also awaited which we also highlighted as an area of concern in our consultation submission). What should tax advisers do now? Preparations should begin now. Tax advisers should act as soon as possible to: Familiarise themselves with the draft legislation and monitor this for any changes. This may necessitate appointing a specific team of individuals within the firm who will be responsible for implementing the legislation and ensuring it is complied with both at the time of registration and in the future, Identify who their relevant individuals are and how many individuals the rules require them to include in their application, Determine their registration timeline now as this information is available from HMRC, Audit, check, and document whether or not the firm and all relevant individuals will meet the registration conditions and take remedial action where necessary, and Ensure that the risk of suspension/prohibition, including the impact of this on their clients and how this would be managed, is built into the firm’s contingency planning.  

Revenue has updated its guidance on emergency accommodation and ancillary services to reflect the change introduced by Finance Act 2025 resulting in the automatic cancellation of all VAT waivers of exemption with effect from 23 December 2025.

In its recently published ‘Beyond the Budget Series', the Irish Fiscal Advisory Council (IFAC) has highlighted concerns that Ireland’s corporation tax receipts have become more concentrated with the top ten highest paying corporate group accounting for almost 60 percent of total corporation tax receipt in 2024. Of this cohort, the top three corporate groups accounted for 46 percent of all corporation tax revenues in 2024. In addition, data shows that since 2022, the corporation tax paid by two of the biggest payers, both in the tech sector, has increased substantially resulting in greater concentration and greater uncertainty. As corporation tax revenues become more concentrated, they also become more volatile. IFAC warns this means Ireland’s tax base is increasingly exposed to the performance of a small number of firms and the decisions they make. The relevant group structures are highly sensitive to global developments and further shifts in US tax, trade, or industrial policy could significantly influence their location decisions. As a result, future receipts are more uncertain and could end up significantly above or below current levels. However, IFAC notes that the 15 percent minimum effective tax rate for large multinationals will boost corporation tax revenues from 2026 with a previous analysis suggesting the measure could raise a further €5 billion in receipts.