Building on the package of tax gap measures which were announced at the Autumn Budget, a further series of announcements were made which included the extension of Making Tax Digital for income tax to even smaller businesses which we report on in more detail in a separate news item. Debt management and compliance investment  According to the government, at the end of 2024, the stock of tax debt (unpaid tax liabilities owed to HMRC) was over £44 billion, more than double the level five years ago. In order to reduce this, the government is further investing in HMRC’s debt management capacity which will include ‘an innovative test and learn pilot to collect more aged debts whilst also moving towards more automated debt recovery.  The government is also investing £87 million over the next five years in HMRC’s existing partnerships with private sector debt collection agencies to collect more unpaid tax debts. An additional £114 million will be invested over the next five years to recruit an additional 600 HMRC debt management staff; 500 more HMRC compliance staff will also be recruited via a £100 million investment.  Late payment penalties  Late payment penalties for VAT and income tax self-assessment taxpayers (as they join MTD) will increase from April 2025 onwards. The new rates will be 3 percent of the tax outstanding where tax is overdue by 15 days, plus an additional 3 percent where the tax is overdue by 30 days, plus an additional 10 percent per annum when overdue by 31 days or more. Consultations  The government also published four new consultations to support HMRC’s efforts in closing the tax gap: How HMRC can make better use of third party data to increase automation and close the tax gap – closes 21 May 2025 Proposals to strengthen HMRC’s ability to take action against those tax advisers who facilitate noncompliance from their clients – closes 7 May 2025 Closing in on promoters of marketed tax avoidance, whose contrived schemes leave their clients with unexpected tax bills – closes 18 June 2025, and Options to simplify and strengthen HMRC’s inaccuracy and failure to notify penalties – closes 18 June 2025. Counter-fraud capability and investigations  Additional criminal investigations will focus on delivering a strong deterrent. This will include tackling those who undermine legitimate trade and small business, fraud committed by the wealthy, fraud facilitated by those in large corporations, and by individuals and companies who make it possible for others to hide money offshore. Investigations will also address organised criminal attacks, focusing on illicit finance and complex money laundering schemes.   As part of the overall investment in HMRC resourcing, HMRC is overhauling its approach to offshore tax noncompliance by the wealthy, recruiting experts in private sector wealth management and deploying AI and advanced analytics to help identify and challenge those who try to hide their wealth, wherever they try to hide it.   During the next five years, the government will increase HMRC’s resources assigned to tackling wealthy offshore noncompliance by around 400 people, who are estimated to bring in over £500 million over the forecast period.   New informant reward scheme  A new HMRC reward scheme for informants will be launched later this year, with the aim of targeting serious noncompliance in large corporates, wealthy individuals, offshore and avoidance schemes. The new scheme will take inspiration from the successful US and Canadian models, rewarding informants with compensation linked to a percentage of any tax taken as a result of their actions.  Phoenixism  To tackle ‘phoenixism’, HMRC, Companies House, and the Insolvency Service will deliver a joint plan to tackle those using contrived insolvencies to evade tax and write off debts owed to others. This includes increasing the use of upfront payment demands, making more directors personally liable for company taxes, and increasing the number of enforcement sanctions to double the amount of tax protected to £250 million by 2026/27.   Change at HMRC  The government will also accelerate change at HMRC, including through introducing voice biometrics, using AI in taxpayer services and compliance, and running a customs digitalisation pilot sharing trusted trader credentials with US Customs and Border Protection.   Tax simplification  Further measures will be announced later in the spring to simplify the tax and customs systems, and in the summer, HMRC will publish a transformation roadmap. These measures will aim to collectively reduce administrative burdens so businesses and individual taxpayers spend less time on tax and customs administration.   Direct recovery of tax debts   HMRC will re-start ‘direct recovery’ of tax debts owed by individuals and companies who have the ability to pay but choose not to do so. The government will also explore options to automate the process for collecting lower value tax debts.   

Revenue has published a new manual RZLT Return which provides information for taxpayers and agents on the process for submitting a Residential Zoned Land Tax (RZLT) return. The manual outlines the process for submitting and amending an RZLT return, and the steps involved in making and viewing a payment of RZLT. An RZLT return must be submitted for each relevant site registered for RZLT and returns may be submitted from 24 March 2025. The first annual return must be filed and any tax due paid on or before 23 May 2025.

Making Tax Digital (MTD) for income tax is being extended to sole trades and landlords with qualifying income of more than £20,000 from April 2028. The Government also announced further changes to MTD as set out in the technical note “Modernising the tax system through Making Tax Digital”, details of which are provided below. The Institute has been engaging extensively with HMRC, together with the other professional bodies, to raise the impact of this major change to income tax reporting on individuals and their agents and the challenges that this will present.  There is now just over a year to the first tranche of mandation of MTD for income tax which will commence from April 2026 for those with gross income of over £50,000 and from April 2027 for those with gross income over £30,000. Even more worryingly, the government has also said that it will continue to explore ‘how it can best bring the benefits of digitalisation to more of the around four million taxpayers who have income below the £20,000 threshold’.  We will be discussing the MTD for income tax Spring Statement measures and announcements with HMRC via various stakeholder forum meetings in the coming weeks and months. Despite our reservations about MTD, the Institute will continue to work with HMRC on MTD readiness and is developing a cross-department MTD strategy to assist members in their preparations. We will also continue to represent members views as we approach April 2026 and will be conducting a short survey on MTD for income tax in next week’s Tax News.  End-of-year tax reporting for MTD   Some users of MTD for income tax will have other sources of income that need to be reported in Self-Assessment (SA). These additional income sources must be reported at the end of the tax year, alongside any necessary adjustments to their business income and expenses.   Previously, users would have been able to use HMRC’s online filing service to submit their final tax return. HMRC has now announced that its online filing service will not be available to do so and that MTD taxpayers must file their tax return through their MTD software. The government will adopt this change and introduce legislation ahead of April 2026.   One or more MTD-compatible software products will therefore be needed to meet SA filing obligations which makes the choice of software used by the agent/taxpayer of extreme importance.   Exempting/deferring certain groups from MTD  The government believes that some taxpayer groups will face disproportionate barriers to operating MTD and should be exempt. The following groups will therefore not be required to use MTD for income tax, (subject to notifying and satisfying HMRC that they are exempt):   taxpayers who have a power of attorney, ·non-UK tax resident foreign entertainers/sportspeople who have no other income sources that count as qualifying income for MTD, and taxpayers for whom HMRC cannot provide a digital service. The following groups will also not be required to join MTD for income tax over the course of this Parliament:   ministers of religion, Lloyd’s Underwriters, recipients of the married couples’ allowance, and recipients of the blind persons’ allowance. Additionally, individuals will not be required to use MTD until April 2027 if they have information that they would need to submit using the SA109 schedule. HMRC will work with stakeholders to finalise the design of a one-year deferral for these groups to allow time to incorporate into MTD the government’s changes to the taxation of non-UK domiciled individuals.   Legislation will therefore be introduced to defer/exempt these groups and the criteria for deferrals/exemptions will be set out in guidance once the legislation is finalised.   Finalising the policy framework for MTD and penalty reform  The government has announced several further changes to the design of MTD and penalty reform. These include:  changes to enable taxpayers with an accounting date of 31 March to start their MTD obligations on 1 April in the first year of operating MTD which will avoid the need for burdensome manual adjustments at the end of the tax year, and a power for HMRC to cancel/reset late submission penalty points and to cancel associated financial penalties; this enables HMRC to cancel penalty points, for instance, in periods prior to insolvency, so that penalty reform reflects HMRC’s general approach to insolvent taxpayers. HMRC will continue to engage stakeholders on these changes before legislation is introduced ahead of April 2026. 

Within the Spring Statement Green Book were a range of miscellaneous measures worthy of mention including news of a new online service for reporting and paying the high income child benefit charge, the launch of a consultation on advance tax certainty for major projects and a consultation on research and development (R&D) advance clearances.   High income child benefit charge (HICBC)   From summer 2025, employees liable to the HICBC will be able to report their family’s child benefit payments to HMRC via a new digital service and they will also be able to opt to pay the HICBC directly through PAYE, without the need to register for self-assessment (SA) and file SA returns.  Advance tax certainty for major projects consultation   At Autumn Budget 2024, the government announced in its Corporate Tax Roadmap that it would be consulting on a new process to provide increased tax certainty in advance for major projects. A consultation has therefore now been launched seeking views on taxpayers’ priorities which also sets out thinking on how a new process could work to support investment decisions. Responses should be sent to advancetaxcertainty@hmtreasury.gov.uk or advancetaxcertainty@hmrc.gov.uk by 17 June 2025.  As part of this, businesses will also be able to obtain certainty on the transfer pricing treatment of cost contribution arrangements through the UK’s existing advance pricing agreement programme.  R&D reliefs advance clearances consultation   The government has also published a consultation on widening the use of advance clearances in R&D tax credits. The aim of the consultation is to explore options to reduce error and fraud, provide certainty to businesses and improve the taxpayer experience. Views are sought on whether a system of advanced clearances would deliver these aims and the best way to design and operate such a system. This consultation closes on 26 May 2025 with responses to be sent to randd.advance.clearances.consultation@hmrc.gov.uk.   

The European Commission has welcomed the European Court of Auditors' special report on VAT fraud on imports. The report emphasises the importance of addressing VAT fraud, with particular regard to simplifying import customs procedures. The Commission aims to better protect the EU's financial interests and ensure a fair and competitive business environment by strengthening the EU's tax legislative framework and improve cooperation between tax and customs authorities with measures such as VAT in the Digital Age (ViDA) and the Import One Stop Shop (IOSS).

The FISC subcommittee will host a public hearing on Thursday 24 April 2025 to discuss the role of tax in aligning the green transition and competitiveness.

As we reported earlier in the month, from 31 March 2025, HMRC launched its new email enquiry service for agents to help escalate and resolve individual (and not employer) PAYE and self-assessment queries which are over four weeks old. More details of how the new service should work are set out in an email to agents. For several years, the Institute has been advocating for HMRC to establish an email enquiry service for agents including in last year’s Pre-Budget submission and in a letter at the end of 2024 to HMRC on services. The Institute participates in the new HMRC Stakeholder Forum, the Customer Services for Tax Agents and Representative Bodies Working Group, which aims to assess current agent services and to develop improved services for agents contacting HMRC with client queries. This new email enquiry service is an output from that forum which will continue its work including reviewing the workings of the new service.   

Last week, the United Nations Committee of Experts on International Cooperation in Tax Matters met to further progress the implementation of its 2021-2025 work plan. The Committee, comprising 25 members representing diverse tax systems and geographical regions, considered emerging tax risks in areas such as the digitalised economy and crypto assets and also discussed tax treaty negotiation and increasing tax transparency.

On 27 March the Ulster Society hosted a webinar with three of Northern Ireland's leading economists who give some insight into the key issues affecting the local economy; and to examine what businesses and policy-makers can do to address the challenges ahead. SPEAKERS: Gareth Hetherington - Director of the Ulster University Economic Policy Centre; Maureen O'Reilly - Independent Economist; Conor Lambe - Chief Economist, Danse Bank. This webinar is available to view, for free and on demand HERE

With major tax deadlines ahead, strategic planning is crucial. Suzanne Mcilwaine outlines the changes on the way from 5 April and how to manage them wisely Announcements regarding Inheritance Tax (IHT) in the 2024 Autumn Budget have had a big impact on the business and farming sectors. Similarly, changes affecting individuals who benefit from the UK domicile and residence rules will significantly alter their tax landscape. While these topics warrant separate discussion, it's essential not to overlook several other changes that affect a broader range of taxpayers, as well as the usual considerations for tax year-end planning. To start, maximising annual tax-free reliefs and allowances before the 5 April 2025 deadline is crucial. Individuals have a personal savings allowance of £1,000 or £500, depending on whether they are basic or higher-rate taxpayers (this allowance is not available for additional-rate taxpayers). For those exceeding these thresholds or looking for a tax-efficient approach, the annual individual savings account investment allowance stands at £20,000. Additionally, contributing to retirement savings can yield significant benefits, with effective tax relief of 20, 40 or even 60 percent available on qualifying contributions, depending on individual circumstances. It’s important to review personal allowances and thresholds relevant to pension contributions before taking action. Those uncertain about their state pension position should apply for a state pension forecast and check their National Insurance (NIC) record for any gaps as soon as possible. This is particularly important, as the opportunity to pay voluntary NICs to bridge gaps from April 2006 to April 2016 will expire after 5 April 2025. Key changes to inheritance tax and capital gains tax There are several exemptions to IHT worth noting. An annual gift exemption allows individuals to give away £3,000 per donor, which can be carried forward for one year to a total of £6,000 if not utilised. Additionally, a small gifts exemption of £250 per beneficiary per tax year is also available. Be cautious with gifts of assets, however, as they may have other tax implications, including potential liability for capital gains tax (CGT). As of 30 October 2024, CGT rates rose from 10 to 18 percent for basic rate taxpayers and from 20 to 24 percent for higher rate taxpayers. The annual exemption for taxable gains is £3,000, so it’s important to use it, or you will lose it. Business owners eligible for Business Asset Disposal Relief will also see changes. The CGT rate on the first £1 million of eligible gains will increase from 10 to 14 percent, starting on 6 April 2025, with a further increase to 18 percent beginning on 6 April 2026. If a sale is anticipated, it is advisable to consider timing and pre-sale planning options sooner rather than later. Implications for property owners and investors The special tax treatment provided for Furnished Holiday Lets (FHL) will be eliminated from April 2025, resulting in the loss of favourable CGT treatment, full mortgage interest relief and Capital Allowances (CAs) on qualifying capital expenditures. FHL owners should re-evaluate their rental models; if short-term holiday lets remain a preferred option, they might consider accelerating qualifying capital expenditure to benefit from CAs while they are still available. Finally, for individuals purchasing residential property, the threshold for Stamp Duty Land Tax (SDLT) will reduce from £250,000 to £125,000, effective from 1 April 2025. Additionally, the surcharge on individuals owning multiple residential properties has increased. Therefore, those looking to buy residential property should be clear about their SDLT liabilities and consider whether expediting their purchase could be advantageous. As with all tax planning, it is essential to consider both non-tax and financial implications, rather than focusing solely on the tax landscape. Suzanne Mcilwaine is a Tax Manager at Grant Thornton in Northern Ireland

As Irish businesses navigate economic uncertainty and technological disruption, Ger Twomey explores key insights from PwC and the WEF on future workforce challenges Irish organisations, like their global counterparts, are facing unprecedented transformation as they navigate technological disruption and economic uncertainty. As such, understanding the future of work has become critical.  The World Economic Forum’s (WEF) Future of Jobs Report 2025 and PwC’s 28th Annual CEO Survey offer valuable insights into the evolving labour market. Drawing on data from over 1,000 leading global employers and close to 5,000 CEOs worldwide, these reports provide a roadmap for Irish organisations and employees preparing for the changing landscape of work. If Ireland’s workforce was represented by just 100 people, 67 would require further training by 2030. To break this down further: 31 could be upskilled within their current roles; 25 could be upskilled and redeployed within their organisations; and 11 would be unlikely to receive the necessary upskilling, putting their future employment at risk. This analogy paints a stark picture of the strategic workforce challenges organisations will face in the coming years. An evolving labour market The WEF's Future of Jobs Report 2025 projects significant changes in the global labour market, with 22 percent of today’s total jobs expected to be affected worldwide. This encompasses both job creation (equivalent to 14 percent of today's employment) and displacement (equivalent to 8 percent of current roles). This dynamic shift is characterised by two key trends. First, frontline jobs in sectors such as farming, construction, food processing and sales are expected to experience the largest growth in volume. Second, technology roles are anticipated to be the fastest growing by percentage. Among the roles poised for rapid growth are big data specialists, fintech engineers, artificial intelligence (AI) and machine learning experts, software developers and professionals in green transition and renewable or environmental engineering. This evolving landscape underscores the critical need for organisations to invest in developing relevant skills. Skills demand The evolution of the job market is driving significant changes in the required skills. The “skill instability” rate of 39 percent suggests that by 2030, two in five workers will need to transform their existing skill sets or risk obsolescence. Skills gaps have emerged as the primary barrier to organisational transformation. In Ireland, 75 percent of respondents identify this as a major challenge for the next five years, compared to 63 percent globally. This concern is echoed in PwC's CEO Survey, in which 91 percent of Irish CEOs express concern over skills availability. There are several skills that appear to be in demand: Analytical thinking remains the most sought-after skill, with 70 percent of organisations deeming it essential by 2025; Resilience, flexibility, agility, leadership and social influence are also core skills; and AI and big data top the list of fastest-growing skills, followed by technology literacy and cybersecurity. Notably, Ireland ranks most of these skills higher in importance than the global average. However, despite the emphasis on AI skills, only one-third of CEOs plan to integrate AI into their workforce and skills strategy, according to the PwC CEO Survey. Navigating the future of work The World Economic Forum's Future of Jobs Report 2025 and PwC's CEO Survey offer crucial insights into the evolving landscape of work. These findings provide a roadmap for Irish businesses to build a resilient, adaptable and inclusive workforce ready for future challenges and opportunities. The global work environment is increasingly complex, influenced by factors such as: Growing geo-economic fragmentation; Rising cost of living; and Widespread adoption of AI tools. Despite these challenges, the outlook remains net-positive for employment. The rate of skills obsolescence is falling, thanks to successful reskilling, upskilling and redeployment initiatives implemented in recent years. Employers across various industries demonstrate a greater awareness and proactivity in addressing workforce challenges. However, skills gaps persist as the primary barrier to transformation. Future priorities are likely to include facilitating proactive and dynamic job transitions, as well as balancing deeper automation with broader workforce augmentation. By embracing these insights and taking decisive action, Irish businesses can position themselves at the forefront of the evolving work landscape, ensuring their workforce is well-equipped for the future. Ger Twomey is Director of Workforce Consulting at PwC

M&A activity in Ireland is growing, but post-transaction disputes continue to be a risk. Clear SPA drafting, due diligence and dispute resolution mechanisms are key to safeguarding deal value, writes Simon Rattigan Currently, there is a sense of positivity surrounding mergers and acquisitions (M&A) activity in Ireland. We saw an increase in private equity-backed transaction activity in 2024 and this is expected to continue this year. The lowering of interest rates will make financing deals more affordable, and Ireland will remain an attractive location for foreign direct investment (FDI). Increased deal activity is encouraging for the economy, but transactions are not without risk, and post-transaction disputes remain a persistent factor in the M&A landscape. Disputes Buyers and sellers generally have different financial incentives, often leading to disputes when expectations set during the deal-making process are not met in the post-closing phase. To help safeguard deal value, it is important to understand the main types of disputes that can arise, including completion account disputes, earn-out disputes and breach of warranty claims. Completion account disputes When completion accounts are used for a transaction, they are typically prepared by the buyer, incorporating adjustments to working capital and other balance sheet items, as specified in the sales and purchase agreement (SPA).  While this mechanism adds complexity, it is generally favoured by the buyer because it provides an opportunity to test the balance sheet, which is appropriate where performance and/or working capital is volatile. Working capital disputes commonly arise when there is a lack of clarity regarding the accounting hierarchy in the SPA, which typically outlines the order of precedence. Issues can arise when: The SPA prescribes a valuation approach for inventory that is not in accordance with Generally Accepted Accounting Principles (GAAP). The SPA states that bad debts should be fully provided for but does not clarify how they will be identified. The SPA requires the application of certain accounting policies but does not specify how judgment under those policies should be applied. The SPA is contradictory – for example, it requires completion accounts to be prepared consistently with historical accounts and practices, as well as in accordance with GAAP. This causes a challenge if historical accounts are not in accordance with GAAP. If the accounting hierarchy in the SPA is unclear, the scope for interpretation and, therefore, disagreement between the buyer and seller increases. Earnout disputes Earnouts are increasingly common features of purchase agreements, where part of the consideration paid to the seller is contingent on measurable, post-closing financial performance targets, such as earnings before interest, taxes, depreciation and amortisation (EBITDA). Earnouts are tailored to each deal and are generally favoured by buyers as they reduce uncertainty and offer cash flow benefits. However, disputes can arise when there is ambiguity in the SPA language regarding calculation methodology or the order of precedence of the accounting hierarchy. This can give rise to issues if there are changes in accounting polices during the earnout period or if the earnout calculation departs from specific accounting policies adopted for other reasons (i.e. preparing accounts for audit). Breach of warranty claims During a transaction, the seller will typically make representations to the buyer about the company regarding material financial, operational, legal, and compliance matters. Disputes can arise from factual misstatements made by the seller, which only come to light post-closing, caused by, for example: Material undisclosed liabilities; Status of key customer relationships and contracts; Compliance of financial statements with GAAP; Undisclosed legal or employment issues; and Fraudulent activity by management or employees. Where factual misstatements are identified post-closing, the buyer may seek to recover losses from the seller if it has suffered financial and/or reputational damage. As post-transaction disputes look to be on the rise, it is important to consider both prevention and cure. Mitigation Avoiding disputes is always preferable, and the risk of earnout disputes and completion account disputes can be mitigated with robust drafting of the SPA: that avoids flexibility/judgement in calculation methodologies; is specific in terms of accounting policies and assumptions; and establishes a clear accounting hierarchy. While misrepresentations may not be preventable, a robust due diligence process can help mitigate certain risks associated with a transaction. However, buyers often only gain full access to the financial and operational information when they take ownership. Post-closing reviews can help buyers identify issues at an early stage, minimise the disruption to the business, quantify the financial impact, and understand legal remedies available. Dispute resolution Disputes can still arise even with a well-drafted SPA, which is why dispute resolution clauses should introduce a level of certainty to the determination process. In most cases, the SPA will refer the matter for independent expert determination, but it is important that these clauses: Establish a clear expert selection mechanism; Preferably, identify the expert, not just the firm. Alternatively, they should be as specific as possible in identifying the required expertise; Clearly establish and limit which items can be disputed; Ensure the role of the expert is clearly defined, and the scope is within their area of expertise – i.e. an accounting expert cannot determine a point of law; and Clearly outline the dispute resolution procedure, including specific timelines. As deal activity in Ireland is expected to grow, post-transaction disputes remain a significant risk. To protect against these risks, businesses should prioritise the robust drafting of SPAs and ensure that clear dispute resolution mechanisms are in place to minimise business disruption. Buyers should also consider conducting post-transaction reviews at an early stage to investigate areas of risk or concern following the deal closing. Simon Rattigan is Director of Forensic and Investigation Services at RSM Ireland