The first Practice News webinar of 2025, brought to you by Practice Consulting, took place on Friday 7 February 2025. In attendance were senior representatives from HMRC’s Making Tax Digital (MTD) team, including the MTD Programme Director Craig Ogilvie and Gemma Hope, from the Agent External Readiness team. Attendees heard how agents and taxpayers can prepare for MTD for income tax, including the benefits of joining its testing programme and key readiness tips. A recording of the webinar is available for viewing here. HMRC’s slides are also available on our website. The webinar also contained the usual regular features including updates on both Irish and UK tax, in addition to the latest compliance and technical news from the February 2025 edition of Practice Matters.

Revenue has updated the Tax and Duty Manual which provides guidance on the provisions relating to the residence of individuals. New paragraphs are included which provide additional guidance on: The meaning of ordinary residence and its implications in relation to the charge to tax (paragraph 2), Details on the charge to tax of income from a public office or employment (paragraph 5) and, Double tax agreements (paragraph 7). Certain paragraphs have been removed as the relevant matters are dealt with in separate Tax and Duty Manuals; these include split year residence and PAYE exclusion orders. The appendices in the manual have also been updated to reflect refreshed examples and now include a summary table on the tax implications of an individual’s residence, ordinary residence, and domicile status. A new appendix has also been included to provide historical guidance relating to a concession applying to Covid-19 cases in 2020.

In a story on 13 January 2025, we highlighted planned industrial action by HMRC staff which at that point was expected to end later this week on Friday 14 February 2025. HMRC has recently contacted us to advise that this action, which affects the Employer Helpline and Construction Industry Scheme helplines, has been extended to 14 March 2025. The full email from HMRC reads as follows: “In December we notified you about industrial action affecting the Employer Helpline and Construction Industry Scheme (CIS) helplines. This has been extended to 14 March. We have robust plans in place to ensure we continue delivering critical services.  HMRC Employer Services phonelines and webchat will be open 8am-6pm as usual but customers may experience longer wait times. We recognise that this is inconvenient for customers and agents who need direct support.   The lines affected are:  Employer Helpline (EHL)   Construction Industry Scheme (CIS) Helpline   There are no expected impacts on other services. We will keep the opening hours and service levels under review, and we will update you in advance of any changes.   We are updating GOV.UK and the recorded message that customers hear when calling the helpline. This tells them about the industrial action, the increased wait times and encourages customers to use our digital services. We strongly encourage customers to use our digital services rather than waiting to speak to us on the phone. Some of the main topics customers call these helplines about, which they can do online are: Get a quick answer to queries using the digital assistant  Check the status of your CIS refund in the ‘Where’s My Reply’ tool – only call us if the date has passed   Check your balance in the Business Tax Account   For technical support with online services use the For technical support with online services use the Online Services Helpdesk.”

HMRC has recently updated the Making Tax Digital (MTD) for income tax taxpayer and agent sign up guidance pages to reflect changes to the eligibility criteria for participating in the MTD for income tax trial in 2025/26. Following these changes, taxpayers reporting the high income child benefit charge and/or income from a jointly owned property will be able to sign up voluntarily to join the MTD for Income Tax 2025/26 trial phase ahead of mandation for the first phase of taxpayers with turnover exceeding £50,000 from April 2026. Further updates on the 2025/26 testing phase are expected ahead of its launch which is currently targeted for April 2025.

In this week’s miscellaneous updates, HMRC has confirmed that its interest rates will be reduced after the recent Bank of England base rate reduction and a consultation is taking place on HMRC statistics. From April 2025, the legislation which gives effect to the UK-Russia and UK-Belarus Double Taxation Treaties in UK law will be revoked and HMRC’s Guidelines for Compliance (GfC) have published the latest GfC on labour supply chain assurance. 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. HMRC late payment interest rates to be reduced HMRC has confirmed that its interest rates for late payments will be revised and reduced by 0.25 percent following the Bank of England interest rate cut to 4.5 percent. These changes will come into effect on: 17 February 2025 for quarterly instalment payments, and 25 February 2025 for non-quarterly instalments payments. HMRC’s information on the interest rates for payments will be updated shortly. Consultation on changes to HMRC statistics publications On 16 January 2025, HMRC published a consultation seeking views on how the statistics they publish are used. HMRC recognises that it is important to engage with statistical publication users regularly and to consider whether publications remain of high value to them. The aim of the proposals is to ensure that HMRC: continues to produce useful and relevant statistics for use by its stakeholders, adding to its existing statistics where appropriate, and adapts statistics publications to reduce what is produced for those which are no longer widely used, are duplicated elsewhere, or could be produced less frequently. The consultation closes on 10 April 2025. Revocation of UK-Russia/Belarus tax treaties Following Russia’s unlawful action to suspend material provisions of the 1994 UK-Russia Double Taxation Convention and the 2017 UK-Belarus Double Taxation Convention, the UK continued to honour its treaty obligations. The UK requested that Russia come back into compliance with its international legal obligations. However, as it did not do so, the UK has now notified Russia of its intention to suspend the Convention. The UK will therefore revoke the legislation which gives effect to these conventions in UK law. These will both cease to have effect from: 6 April 2025 for Income Tax and Capital Gains Tax, and 1 April 2025 for Corporation Tax. The UK will continue to honour its obligations under the treaties until these dates. However, thereafter, there will be an increased risk of double taxation, with a need to rely on the relief (if any) available under domestic law noting the potential for this to be restricted by ongoing sanctions. The following publications have therefore been updated: Belarus: tax treaties, and Russia: tax treaties. New GfC on labour supply chain assurance HMRC’s GfC team has published Help with labour supply chain assurance — GfC12. The guidelines are designed for larger organisations in the top tiers of a labour supply chain; however, the principles can be applied to most businesses. HMRC continues to tackle tax defaulters in labour supply chains directly. Many risks arise where there are opportunities to exploit larger, higher value, and more complex chains. HMRC is concerned about how these risks can affect a business’s own tax affairs. These guidelines explain how taxpayers can self-assess their own assurance practices and aim to help taxpayers identify and limit the impact of risks. The guidelines: explain what labour supply chains are and the associated risks, promote the importance of effective labour supply chain assurance, and provide practical advice to consider when carrying out labour supply chain assurance. These have been produced using a different format than previous guidelines hence HMRC is keen to hear feedback on the new format. If you have any queries or feedback, please contact the GfC Mailbox. Alternatively, there is an anonymous survey in the Next steps, further questions and feedback section.

Revenue has updated the Tax and Duty Manual Guidance on the Residential Zoned Land Tax (RZLT) to reflect Finance Act 2024. The main changes to the manual reflect amendments to the sections dealing with land subject to the RZLT, administration, exemptions, deferrals and abatements and other issues.

The Commission’s priorities on tax matters were outlined in a recent address to the European Parliament’s tax matters subcommittee. Commissioner Hoekstra said that simplifying and fraud-proofing the EU’s tax laws, further reforming VAT rules, favouring renewable energy through tax policy, and better addressing the tax gap would be some of his main priorities. The Commissioner also confirmed that he will look for opportunities to engage constructively on Pillars One and Two with the US Administration in light of the recent US executive order on the OECD global tax deal.

Last week Revenue published statistics relating to 2024 PAYE tax returns filed to date this year on the back of which PAYE taxpayers are being encouraged to use the myAccount service to finalise their tax position. The statistics showed that as at 29 January 2025, over 550,000 PAYE returns had been processed for 2024 which resulted in refunds of over €400 million to PAYE taxpayers. Revenue is reporting a continuing increasing trend in the use of Revenue’s my Account service to file tax returns. An underpayment of tax arose in approximately 12 percent of the returns processed and Revenue has advised that they will engage with the relevant taxpayers to collect the tax due by reducing tax credits over a four-year period. Revenue has reported they estimate a further €389 million of tax may have been overpaid by PAYE taxpayers in 2024. In light of this, Revenue has launched a campaign to encourage PAYE taxpayers to use the myAccount service to finalise their tax position. Revenue has provided details on how to access this service and detailed guidance on submitting a PAYE tax return and claiming tax credits and reliefs.

At a recent public meeting hosted by the FISC subcommittee on tax matters, experts discussed ‘A coherent tax framework for the EU’s financial sector’. The forum considered innovative solutions for the taxation of the EU's financial sector to further integration, facilitate cross-border operations and foster digitalisation and innovation. The hearing also considered the challenges stemming from the current VAT exemption for financial services.

In this week’s post EU exit corner, we bring you the latest guidance updates and publications relevant to 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. Bookings are now open for a HMRC webinar next week on the new arrangements for the movement of parcels and freight between Great Britain and Northern Ireland which commence from 31 March 2025, delayed from 30 September 2024. For more information, click read more. HMRC webinar on new arrangement for parcels and freight The Windsor Framework establishes a new set of arrangements for the movement of goods between Great Britain and Northern Ireland via both parcels and freight. HMRC has organised a free webinar on Monday 24 February 2025 from 2-3pm to help businesses that make parcel movements between Great Britain and Northern Ireland prepare for the new arrangements by 31 March 2025. HMRC is encouraging interested parties to sign up. This webinar follows on from the webinar held on 21 November 2024, which you can view the recording of on the newly launched WF resource page. On the day, the webinar will cover:  What the new parcel arrangements are, The UK Internal Market Scheme (UKIMS) and how to send business to business parcels under UKIMS, Illustrative parcel journeys for consumer and business parcel movements, and A Q&A slot. To register and pre-submit any questions, please click this link. You are also reminded to save the invite to your calendar once registered. Miscellaneous guidance updates and publications Multinational companies and companies based in both GB and NI Economic Operators Registration and Identification (EORI), EORI, Who should register for an EORI number, Place of registration, Finding and checking an EORI, and Location codes for ports of entry in Great Britain.  

The Department of Finance and the Department of Public Expenditure and Reform have published the Fiscal Monitor for January 2025 which confirms an Exchequer surplus of €3.6 billion in January. This compares to a surplus of €2.3 billion recorded for January 2024. Tax receipts collected in January were €10.1 billion, which was €2.3 billion ahead of the same period last year. Excluding the once off receipts arising from the judgement of the Court of Justice of the European Union (CJEU) in the Apple State aid case, total receipts of €8.4 billion were collected in January, ahead by €0.6 billion on the same period last year. Income tax receipts of €3.0 billion were recorded in January, €0.1 billion ahead of January 2024. Although January is not generally a significant month for corporation tax, receipts of €1.8 billion were collected in the month which was an increase on January 2024 by just under €1.8 billion, due almost entirely to once-off receipts arising from the CJEU ruling. January is a VAT-due month and generally the strongest VAT month of the year, encompassing the Christmas trading period. Receipts of €4.1 billion were collected in the month, up by 5.8 percent compared to January 2024. Excise duty receipts of €0.5 billion were collected in January, up by €27 million on the same month last year. Commenting on the figures, Minister for Finance, Paschal Donohoe said “Today’s figures show that tax revenues continued to demonstrate steady growth at the start of the year. In particular, the ongoing expansion of income tax and VAT receipts are a positive indicator of the fundamental strength of our economy. However, there are clear risks ahead. As a small open economy, Ireland is particularly vulnerable to changes in the global economic environment. This underlines the importance of continuing to pursue a balanced and sustainable fiscal policy. That is why Government has committed to using the once-off proceeds from the CJEU decision to improve our stock of infrastructure, as well as investing windfall tax revenues in the Future Ireland Fund to prepare for future challenges.”

The OECD has published the latest peer review results on preferential tax regimes under BEPS Action 5. The results highlight the progress made by jurisdictions in addressing harmful tax practices through the implementation of BEPS Action 5.