Following on from our story on Monday in which we highlighted the Institute’s plans to flag our concerns about the 2023/24 self-assessment online filing deadline to HMRC in the context of the recent storms, the Institute requested that HMRC take a pragmatic approach to this issue. We can now share the outcome of those discussions after receiving an update from HMRC. This confirms that whilst a blanket easement is not possible, HMRC will take a sympathetic approach towards those filing after the deadline on a case by case basis. The Institute therefore recommends that if a return is filed late because of the recent weather, the additional information box should be completed to outline the specific reason(s) why and claim reasonable excuse. HMRC will therefore cancel penalties where taxpayers can provide a reasonable excuse. The full update from HMRC is as follows: “ Thank you for raising the possible impacts of the recent severe weather across parts of Ireland and the UK on people and businesses in the run up to the Self Assessment deadline. Undoubtedly, this would have impacted some individuals, businesses and agents still trying to submit SA returns. Given the timing of these very recent events and the fact that areas most impacted are difficult to identify, we are not in a position to invoke a unilateral easement. We will however take a sympathetic approach towards those filing after the deadline on a case by case basis. We don’t want to collect penalties – our aim is to support taxpayers to get their tax right and avoid fines. We will cancel penalties where taxpayers can provide a reasonable excuse within 30 days of the penalty being issued, in which case no financial fine is levied. We will of course take into account the impact of adverse weather when it comes to such appeals. We will also take steps to ensure that teams reviewing forthcoming appeals are alert to the detail of the guidance and will apply it empathetically, appropriately and consistently. Please be reassured that HMRC will be delivering a fair, even-handed and consistent approach across everyone impacted in whatever capacity.” By way of reminder, those without a reasonable excuse will be issued with a penalty including: an initial £100 fixed penalty, which applies even if there is no tax to pay, or if the tax due is paid on time, after 3 months, additional daily penalties of £10 per day, up to a maximum of £900, after 6 months, a further penalty of 5 percent of the tax due or £300, whichever is greater, and after 12 months, another 5 percent or £300, whichever is greater. 31 January 2025 is also the due date for paying any remaining income tax and Class 4 national insurance contributions for 2023/24 and is also the first self-assessment payment on account deadline for 2024/25.

In Irish news, Revenue has issued two new Tax and Duty manuals which outline both the registration requirements and the operation of the residential zoned property tax, and new guidance has been published on the close company surcharge. In UK news, we issue a reminder that the 2023/24 online self-assessment filing deadline is Friday 31 January 2025, and the Institute responds to the HMRC consultation on new ways to tackle non- compliance. In International news, the US President has published a memorandum stating the Two-Pillar Solution has no force or effect in the US. Ireland 1. Revenue has published two new Tax and Duty manuals on the operation of residential zoned property tax (RZPT) and the registration obligations for this tax. 2.Read about the updates to the Tax and Duty manual on the close company surcharge. UK 3. Read about the 2023/24 online self -assessment filing deadline and the possible impact of Storm Éowyn. 4. The Institute recommends that HMRC should review its existing compliance powers before introducing any new powers. International 5. President Trump publishes a Memorandum on OECD Global Tax Deal stating that the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy has no force or effect in the United States. Keep up to date with all the latest Irish, UK, and international tax developments through Chartered Accountants Ireland’s Tax Newsletter. Subscribe to the Tax News by updating your preferences in MyAccount. You can also read this week’s post EU exit corner here.  

On Tuesday, 18 March 2025, the European Commission and the European Parliament will co-host the third EU Tax Symposium. The event is to bring together finance ministers, politicians, policymakers, academics and others to discuss the future of EU tax systems under the theme Strengthening Competitiveness and Fairness to Build Prosperity. Registration is now open for the symposium which will take place in Brussels and will also be livestreamed.

Following his inauguration on 20 January 2025, the President of the United States of America, Donald Trump, has published the Presidential Actions. The publications include a Memorandum on the OECD Global Tax Deal which states that the OECD’s Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy has no force or effect in the United States.

On 29 January the Ulster Society hosted a webinar to brief newly qualified Members. This webinar was designed to help recently qualified members (within the last three years) to get the most out of their qualification and their career - but all members are very welcome to watch. Event Focus: •    CPD Requirements: Understand your Continuing Professional Development obligations and how to meet them. •    Career Advice: Explore resources and guidance for planning your next steps. •    Networking & Mentoring: Connect with peers and experienced professionals for support and opportunities.  confidence and open doors to new opportunities A recording of this webinar is available to view, for free and on demand, HERE A pdf copy of Joe Carroll's slides, as shown in the webinar are available HERE A pdf copy of Karin Lanigan's slides, as shown in the webinar are available HERE

Chartered Accountants Worldwide has launched its inaugural global report into the resilience of the Chartered Accountancy profession— a groundbreaking study conducted by Chartered Accountants Worldwide Wellbeing Taskforce in collaboration with the Resilience Institute. View the Global Wellbeing Report here.  This report examines the state of resilience and well-being within the Chartered Accountancy profession, drawing on insights from a global survey of 697 Chartered Accountants. While Chartered Accountants play a critical role in safeguarding financial integrity, their work often entails significant stress and complexity. Dive deeper into the Global wellbeing report with the experts behind the research. In this must-watch companion episode of Difference Makers Discuss, the report’s authors and the Dee France, Chair of the Chartered Accountants Worldwide global wellbeing taskforce break down key insights and share immediately actionable tips to help you thrive—both professionally and personally. Watch now and start making positive changes today: Building Resilience and Well-Being in the Accountancy Profession The survey highlights key strengths—curiosity, altruism, and creativity—that drive success within the profession. However, it also uncovers challenges such as multitasking, avoidance, and worry, which can erode resilience and mental health. Addressing these issues through targeted skill development and resilience training presents an opportunity to foster a thriving and sustainable profession. As trusted advisors and business leaders, Chartered Accountants have a unique chance to lead by example, cultivating workplace cultures where well-being is not an afterthought but an integral part of daily practice. By prioritising resilience, the profession can set a powerful precedent, showing that success and well-being can—and must—go hand in hand. Dee France, Wellbeing and Support Lead at Chartered Accountants Ireland and Chair of the Chartered Accountants Worldwide Wellbeing Taskforce commenting on the findings said "It's important to look at the challenges within the profession and the one that came up in the study itself; multi-tasking, hyper vigilance and poor sleep quality were defined".  View the Global Wellbeing Report

Recent trends The Institute’s Professional Standards Department has recently seen an increase in the frequency and complexity of proposed restructures of accounting and audit firms including: Institute firms acquiring or merging with other accounting and audit firms; Changes in a firm’s principals (retirements, additions); Creation of new firms within a firm network structure (including the splitting of an existing firm into a number of smaller firms sometimes with a focus on a particular business line or jurisdiction); Interests in a firm being fully or partially acquired by larger firms or other external investors including the involvement of private equity investors in firm/network ownership structures. These trends are observed in both Ireland and the UK. Early engagement with the Institute advised Firms who are considering a change in the firm’s structure or ownership are advised to engage with the Institute’s Professional Standards Department at an early stage in the process.  Such early engagement is important to ensure that any impact on existing or proposed firm authorisations, and/or on the AML supervision of any entities in the structure, is fully understood and properly planned for.  Law and Institute Regulations in both Ireland and the UK set out detailed eligibility criteria which must be met by firms authorised in reserved areas such as audit and investment business.  These eligibility criteria include specific requirements regarding the qualifications of principals and those having ownership/control at authorised firms.  While Institute Regulations require firms to notify the Institute promptly after a change in circumstance which could impact authorisations takes place, firms will benefit from early engagement with the Institute in relation to proposed restructuring transactions.  Firms will, no doubt, want to avoid a situation where a significant transaction concerning the firm’s structure has taken place only to discover that the revised structure negatively impacts the firm’s eligibility for authorisation in a key area. Firms considering a restructure should contact the Institute at authorisations@charteredaccountants.ie.  The Institute will advise the firm regarding the information which should be shared with the Institute initially and as the restructuring plans progress.  The Institute will request information to enable a full understanding of the proposed restructure and the impact on the firm’s eligibility for authorisation(s).  Such information is likely to include the detailed agreements and documentation underlying a transaction such as revised partnership agreements, constitutional documents such as articles of association and where relevant, service level agreements between entities within the revised structure. Frequently, the complexity of restructuring transactions requires that the Institute dedicates significant time to review the relevant documentation, engage with the firm’s principals and conclude in relation to ongoing or new authorisations as a result of a firm restructure.  A firm’s engagement with the Institute early in the restructuring process helps ensure sufficient time for Institute consideration and for the processing of any new applications for individual or firm authorisations arising. The Institute cannot provide legal advice in relation to potential firm structures.  The Institute assesses information provided to conclude whether the Institute can continue to provide authorisations to the restructured firm(s) in reserved areas in accordance with the Institute’s Regulations. Oversight bodies In certain cases, it may also be appropriate for a firm and/or the Institute to engage with relevant oversight bodies such as IAASA or the FRC.  For example, an audit firm which is registered with the FRC as a UK public interest entity (PIE) auditor will be obliged to share information with the FRC in relation to a transaction which could impact UK audit registration. Fees For new notifications of restructuring arrangements received on or after 1 January 2025, the Institute may charge a separate fee to firms for the consideration of the impact of a firm restructure on a firm’s authorisations in reserved areas and/or on AML supervision where relevant.  The fee will be dependent on the complexity of the proposed restructure and the work involved in the Institute’s assessment of all relevant information.  This fee will contribute to the cost incurred by the Institute in the consideration of the proposed restructure and may include a contribution towards any legal advice which the Institute needs to undertake in this regard. Further information Any queries in relation to any of the matters raised above can be directed by email to authorisations@charteredaccountants.ie

On 28 January the Ulster Society held a thought-provoking webinar addressing the pressing challenges organisations face around skills and talent. This lunch-time session explored: The anticipated impact of the Programme for Government for Northern Ireland on skills policy. Current trends in Higher Education and Further Education and their role in shaping the workforce. The latest research on changing skills demands, including the influence of AI and sustainability commitments. Real-world examples of how leading local organisations in all sectors are tackling skills gaps, encouraging returners to work, fostering upskilling and training, and dealing with talent attraction and retention. Our panel of experts shared their insights and experiences, offering practical takeaways that apply across all sectors. A recording of this webinar is available to view, for free and on demand HERE

Revenue has recently updated two other Tax and Duty Manuals. Details are set out below. The updated manuals are as follows: Electronic Relevant Contracts Tax system to include further links to additional information on the operation of this tax. The additional links relate to relevant operations, principal contractors and subcontractors. The Unpaid Remuneration manual to remove a reference to section 989 TCA 1997 and to update an example.

Revenue has updated the Tax and Duty Manual on the Controlled Foreign Company (CFC) rules to includes changes made in the Finance Act 2024 and Finance Act 2023. The changes are as follows: An amendment to the provision providing for the Irish defensive measures in respect of the CFC rules and to include the updated EU Code of Conduct list of non- cooperative jurisdictions for tax purposes Amendment to the rules for calculating ‘undistributed income’ of the CFC arising from the introduction of the new corporation tax exemption for certain foreign dividends Pillar 2 related amendments to the CFC rules for creditable tax and effective tax rate exemption.

Revenue has updated the Stamp Duty Manual Part 7 Section 83D- Repayment of Stamp Duty where land used for residential development. The manual applies to single dwelling and multi-unit developments. The updated manual contains new and updated examples and guidance on record retention and information dissemination. It also includes two new appendices which contain the following: Appendix 1 includes a checklist of the conditions to be satisfied to qualify for a repayment and also the conditions to be satisfied to avoid a clawback. Appendix 2 contains a comprehensive guide on how to make a repayment claim using Revenue’s eRepayments system. 

Revenue has updated the Tax and Duty Manual on leases of farmland to reflect a Commission Regulation increasing the allowable ceiling of de minimis aid from 16 December 2024. Section 81D of the Stamp Duties Consolidation Act 1999 provides relief from stamp duty for a lease of farmland whose term is not less than six years and does not exceed 35 years. In addition, the lands must be used exclusively for farming carried on by the lessee on a commercial basis and with a view to the realisation of profits. This relief is considered a State Aid therefore the manual has been updated to increase the allowable ceiling from €20,000 to €50,000 with effect from 16 December 2024. The manual has also been revised to note that the ceiling applies to the amount of all de minimis aid that is granted in accordance with the Regulation, whether given by way of tax relief or direct grants.