The Pillar Two registration deadline for in-scope entities with a fiscal year ending on or before 31 December 2024 is 31 December 2025. At a recent Main TALC meeting, Revenue’s Large Corporates Division (LCD) highlighted that the number of registrations to date remains low. Revenue outlined the importance of completing registrations well ahead of the deadline and urged practitioners to ensure that any clients within the scope of Pillar Two are registered on time. Revenue had previously sent a letter to Irish companies who may be in scope of Pillar Two taxes, advising them of their registration obligations. The Pillar Two registration link can be found on the ROS homepage under ‘Other Services’. Further details are outlined in an earlier newsletter item.

Revenue has published a further warning of fraudulent emails, SMS (text messages) and phone calls seeking personal information from taxpayers. The press release outlines that Revenue has recently had sight of scam emails which claim that a taxpayer is “due an audit” and which include a link requesting the taxpayer to arrange the audit by a specified date. These messages are not from Revenue. Revenue will never contact a taxpayer by email, SMS or phone call to inform you of a tax refund or bill. Taxpayers who have provided Revenue account details in response to an email, SMS or phone call are advised to reset their password immediately. Taxpayers are advised to contact their bank or credit card provider if they have provided bank or card details.

Following the Budget, HMRC sent an email setting out key details that will directly affect tax agents, in addition to information that might be useful for their clients, or which agents may receive enquiries about. HMRC also confirmed that as set out at the Budget, the Finance Bill includes the legislation that requires tax advisers who interact with HMRC on behalf of clients to register with HMRC and meet certain eligibility conditions. This requirement was due to take effect from April 2026 but has now been delayed to take effect from May 2026. HMRC expects to publish detailed guidance on this next month. Chartered Accountants Ireland responded to the consultation on the draft legislation for this measure in September and had recommended that the measure be delayed. Our submission also recommended that the meaning of tax adviser be restricted to only require those at the highest level working in tax to be within the scope of the rules. The draft legislation now published confirms that this recommendation is largely being implemented for organisations with more than six officers (as defined). Officer is defined as follows: “(a) in relation to a company, a director; (b) in relation to a body corporate whose affairs are managed by its members, a member who exercises functions of management with respect to it; (c) in relation to a body corporate not within paragraph (a) or (b), an officer of the body whose functions correspond to those of a director of a company; (d) in relation to a partnership, a partner; (e) in relation to any other organisation, a person who exercises functions of management with respect to it.” Clauses 222 and 223 of the Finance Bill sets out details of the application process and who within that process is a relevant individual and officer whose details must be included in the application for registration.  More details are available in the associated policy paper which confirms that there will be a three-month transition period. Further details on registration timelines and the transition arrangements for specific tax adviser groups will be communicated by HMRC to stakeholders in advance. The Institute has been engaging with HMRC in the previous weeks and months as HMRC developed this amended draft legislation and will continue to do so.

Revenue has updated its guidance on deposit interest – whether a trading receipt to outline when deposit interest can be treated as a trading receipt. The guidance confirms that to qualify as a trading receipt, the funds must be considered an integral aspect of the trade. The guidance also clarifies that in general, interest earned on funds placed on deposit, which are deemed to be in excess of a company’s business needs, are not considered income taxable under Case I. This is on the basis that Revenue deems such funds as not being integral to the company’s trading activities.

Revenue has updated its guidance on small, self-administered pension schemes in relation to references in the document to Pensions Branch, High Wealth and Financial Services Division. Certain references to tangible moveable asset have also been updated and the guidance now includes the deemed distribution provisions.

Revenue has updated its guidance for trading lessors of certain short life plant and machinery. The general guidance on finance and operating leases has now been moved to the guidance on the Leasing of Machinery or Plant: General Principles of Taxation. In addition, certain outdated material relating to the taxation of specified assets has been removed.

The Government made two announcements at the Budget as part of its ongoing Tax Administration Framework Review (TAFR) project on the correction of errors (there will be a consultation in 2026 on new HMRC powers obliging taxpayers to correct inaccuracies where they are identified) and reform of behavioural penalties. HMRC subsequently sent a detailed update on the next steps for both of these in addition to its ongoing dispute resolution reform work. Earlier in the year Chartered Accountants Ireland responded to the associated consultations on new ways to tackle non-compliance (which contained the proposals on correction of errors) and reform of behavioural penalties. On modernising the correction of errors, HMRC is progressing work on key design elements of the proposals, including the introduction of a general obligation to correct. According to HMRC, the feedback received through this consultation indicated that this measure would be a welcome addition, hence legislation will be drafted for stakeholder input which will take place via bespoke sessions in early 2026. On behavioural penalty reforms, HMRC is currently working through the detailed policy design, including some of the operational practicalities, ahead of moving onto drafting legislation. As this work continues, it will bring up policy choices which HMRC will discuss with stakeholders ahead of publishing any draft legislation.  HMRC has also been analysing the responses received to the consultation on improving HMRC's approach to dispute resolution and is continuing to develop options and prepare a summary of responses for publication. HMRC is also working on launching a new quarterly update which will provide more regular TAFR news; the first edition is currently in development.

The guidance on the income tax treatment of married persons and civil partners has been recently updated by Revenue providing additional information including  details on the three bases of assessment for married couples and civil partners. The relevant updates to the document are: The increase in the standard rate tax band and tax credits, as provided for by Finance Act 2024 and effective from 1 January 2025, with the examples throughout the guidance updated accordingly.   Paragraph 1.1 has been inserted to provide a tabular style summary of the three bases of assessment available to married couples and civil partners. Paragraph 4.2 provides additional guidance on the application of joint assessment and the nomination of the assessable spouse or civil partner. Paragraph 5.2 includes further clarifications on cases where both spouses or civil partners are non-resident, and one spouse or civil partner has income chargeable to tax in Ireland. A new example has been included to outline the tax treatment of a married couple who separate.

The Department of Finance and the Department of Public Expenditure and Reform have published the Fiscal Monitor for November 2025 confirming an Exchequer surplus of €10.4 billion to the end of November. This compares to a surplus of €13.8 billion recorded for the same period last year (what was impacted by receipts arising from the Court of Justice of the European Union (CJEU) ruling in the Apple State Aid case). When these receipts are excluded from total receipts in 2024 and 2025, an underlying surplus of €7.1 billion was recorded which represents an improvement of €2.8 billion on the same period last year. Tax receipts collected to the end of November were €98.7 billion, which was €0.4 billion lower than the same period in 2024. Excluding the once off receipts from the Court of Justice of the European Union (CJEU) judgement in the Apple State Aid case, total receipts amounted to €97.0 billion, an increase of €7.3 billion on the corresponding period in 2024. Income tax receipts for the month of November were €5.1 billion which was €0.4 billion ahead of receipts collected in November 2024. On a year-to-date basis, receipts to the end of November of €33.7 billion were up by €1.5 billion (4.6 per cent), when compared to end of November 2024. Corporation tax receipts of €10.0 billion were collected in November, which is down by €3.7 billion on the same month in 2024. On a cumulative basis, receipts of €31.1 billion were down by €3.9 billion on the same period last year. When the once-off CJEU receipts are excluded, cumulative corporation tax receipts to November 2025 amounted to €29.4 billion, up on the same period last year by €3.8 billion. VAT receipts collected in the month were €3.4 billion with cumulative receipts recorded of €22.5 billion to the end of November 2025 which were ahead by €1.1 billion on end of November last year. Commenting on the figures, Tánaiste and Minister for Finance, Simon Harris said: “Today’s figures are in line with the revised projections for tax revenue that we set out in Budget 2026: strong income tax and VAT returns reflect the strength and resilience of our economy, while corporation tax remains at an elevated level. Government is committed to making sure our spending commitments are sustainable and built on solid foundations. We will continue to run budget surpluses and continue to invest in the Future Ireland Fund and the Infrastructure, Climate and Nature Fund”

The announcements in this area range from changes to VAT groups to a new charitable VAT relief which will commence from April 2026. VAT groups The Government has removed the requirement to consider Revenue and Customs Brief 18 (2015): VAT grouping rules and the Skandia judgement when making cross-border transactions between members of a VAT group. According to HMRC, this returns the UK to its previous position of operating ‘unmodified whole-entity VAT grouping’. This measure took effect from 26 November 2025. HMRC has therefore published Revenue and Customs Brief 7 (2025): Revised VAT grouping rules and the Skandia judgment as a result which sets out the updated position in detail. Under the new ‘whole-entity VAT grouping’ principle, HMRC now considers an overseas branch of a UK VAT group member to be part of the UK VAT group, even if that branch is in a separate VAT group in an EU member state. As a result, such transactions are now disregarded for UK VAT purposes. Charity tax relief From 1 April 2026 a new VAT relief will be introduced for business donations of goods to charity for distribution to those in need or use in the delivery of their charitable services. The relief will remove the requirement for businesses to account for VAT on eligible goods that are donated for onward distribution or use in a charity or eligible organisation’s services. Value limits will apply to donated items to safeguard against misuse, with higher limits available for listed goods. More information is available in a policy paper. Private hire vehicle services From 2 January 2026 suppliers of private hire vehicle and taxi services will be excluded from the scope of the Tour Operators Margin Scheme, except where these are supplied in conjunction with certain other travel services. Deposit return schemes (DRS) In an effort to simplify administration of the DRS, the Government will remove the requirement for individual producers to account for VAT on unreturned deposits. Instead, this will be done by the Deposit Management Organisation. Land intended for social housing A consultation is to be launched in early 2026 on the reform of VAT rules to incentivise the development of land intended for social housing. Landfill tax From 1 April 2026 the standard rate of landfill tax will increase by RPI inflation and the lower rate will increase by the cash amount of the increase in the standard rate. However, the Government has decided not to proceed with transitioning to a single rate of this tax by 2030 and the exemption for quarries with disposal permits will be retained. This was confirmed in the Government’s consultation response published on Budget day. Plastic packaging tax (PPT) To incentivise businesses to use recycled instead of new plastic in packaging, the PPT rate for 2026/27 will increase in line with Consumer Price Index (CPI) inflation. A consultation will also be launched in early 2026 on the introduction of mandatory certification for mechanically recycled plastic packaging for businesses to claim an exemption from the PPT. Finance Bill 2025/26 also provides for a mass balance approach to be used to attribute chemically recycled plastic for the purposes of the PPT from 1 April 2027. This draft legislation also removes pre-consumer waste as a source of recycled content from the same date. Soft drinks industry levy (SDIL) From 1 January 2028 the threshold at which the SDIL applies will be reduced from 5g to 4.5g sugar per 100ml and the exemptions for milk-based and milk substitute drinks with added sugar will be removed. Open cup beverages, such as those bought in cafes, will remain unaffected. The Government also published a summary of responses to its consultation on these reforms. From 1 April 2026 the SDIL will also increase in line with CPI inflation plus one fifth of the ‘catch-up’ increment to reflect the 27 percent CPI increase between 2018 and 2024.  

You may have read on Friday that it has been brought to our attention that the recently launched MyFutureFund employer registration portal may potentially allow individuals with restricted ROS access to view sensitive payroll-related information. This presents significant privacy concerns under the GDPR and requires immediate investigation. Last week, we requested clarity from the Department of Social Protection (DSP) and raised a formal query regarding access controls. At present, we are still awaiting a response, although we understand that the DSP is looking into this. Members are advised to exercise caution when using the portal and report any anomalies. We will keep members informed on this issue.

Readers are reminded that next Monday, 15 December 2025, is the payment deadline for capital gains tax (CGT) liabilities arising in the period 1 January to 30 November 2025. Revenue’s CGT webpage details how to register for CGT via MyAccount. CGT payments can be made online using a debit/credit card or a one-off single debit instruction.