As US President Donald Trump presses ahead with his tariff-led trade policy, John O'Loughlin considers the Irish, UK and EU response and offers his advice to businesses on managing the risks  On Monday, 10 February, President Trump signed a proclamation imposing a 25 percent tariff on all steel and aluminium imports, irrespective of the country of origin, due to be implemented on 12 March. While tariffs had already been in place for both steel and aluminium, certain countries, including the UK and countries in the European Union (EU), were previously exempted. The introduction of Trump’s new policy measures will now see the 25 percent tariff apply to all third countries, including those in the EU. Additionally, on Thursday, 13 February, President Trump signed a Presidential Memorandum introducing the “Fair and Reciprocal Plan”. This plan instructs the Trump Administration to investigate and produce a report detailing proposed remedies to counter non-reciprocal trading arrangements with trading partners. In the context of this memorandum, the potential introduction of “reciprocal tariffs” would see the US apply tariffs to third country goods matching the tariffs those countries impose on US goods.  For example, the White House Fact Sheet accompanying this memorandum specifically highlighted the disparity between the 10 percent tariff imposed by the EU on imported cars, compared to the US tariff of 2.5 percent. Irish reaction In response to the implementation of US tariff measures on China, and the threat of further tariffs being imposed in the EU, the Irish Government has proposed two new advisory bodies.  The Strategic Economic Advisory Panel would be based in the US and specifically tasked with strengthening US-Irish relations and advising on how to address potential policy changes introduced by the Trump administration. The plan is that the panel would comprise influential professionals drawn from a range of business sectors operating in the US. The second proposed body is the Consultative Group on International Trade Policy, which would facilitate dialogue with key stakeholders in international trade. This group would meet at least once every eight weeks, providing guidance on addressing trade challenges and opportunities. EU commentary European leaders have expressed concerns about President Trump’s recent tariff threats, warning of potential economic harm to EU member states. Spain’s Economy Minister Carlos Cuerpo stressed the need for a united EU response to protect businesses and ensure fair competition.  At a recent summit, European Commission President Ursula von der Leyen acknowledged the growing uncertainty surrounding US trade tariffs and affirmed the bloc’s readiness to defend itself. “When targeted unfairly or arbitrarily, the European Union will respond firmly,” von der Leyen stated. Discussions also focused on maintaining transatlantic unity while seeking diplomatic solutions to prevent escalating trade tensions.  French Foreign Minister Jean-Noël Barrot urged the European Commission to take decisive action, arguing that the EU must be prepared to implement retaliatory measures if necessary. His position reflects a broader consensus among EU leaders to stand firm against unwarranted economic actions that could harm European businesses and consumers. More recently, on 10 February 2025, the EU Commission issued an official statement regarding potential US tariffs on EU-sourced steel and aluminium. The Commission emphasised that it would not respond to any announcements without written clarification and reiterated that it sees no justification for imposing tariffs on its exports. Echoing the sentiments of the foreign ministers of EU member states, the Commission affirmed that any future actions would aim to protect the interests of European businesses, workers and consumers against unjustified measures. UK position In contrast to the EU, President Trump has made generally positive comments relating to the UK, suggesting that potential UK tariffs could be “worked out”. This has resulted in a subdued response from the UK, with no clear signs that a trade war could break out between the two nations. Preparing for the future Since the inauguration of President Trump, we have seen increased engagement from businesses on the tariff issue, motivated by a desire to understand the practical implications of these changes and how they might impact business performance. To determine this potential impact, companies should take the following steps: Assess the customs origin of goods shipped to the US to determine exposure to potential tariffs. Gain oversight of the end-to-end supply chain, gathering the right data to assess the impact on material sourcing and tariff exposure for component parts. Understand how tariffs might impact software/service business due to reduced demand from existing customers. Assess the legal structure of the business and how transfer pricing arrangements could be used to mitigate tariff impact. John O'Loughlin is Partner of Global Trade and Customs at PwC Ireland

Ireland’s pension system stands at a critical juncture driven by evolving market conditions and demographic shifts. Rav Vithaldas delves into the details The pension market in Ireland is characterised by a growing shift towards defined contribution (DC) schemes, consolidation and regulatory compliance. Our pension system comprises a basic state pension, employer-provided occupational schemes and private personal plans, all incentivised with tax benefits and options for voluntary contributions. According to the Central Bank of Ireland (CBI), the total assets of the Irish pension fund sector increased by 2.4 percent in the third quarter of 2024 to total €142 billion. The most prominent pension funds among our occupational pension schemes include master trusts, designed to provide a governance structure that allows multiple employers to participate in a single, centrally administered, pension arrangement. This can be particularly beneficial for small and medium-sized enterprises (SMEs) that may not have the resources to manage their own standalone pension schemes. The introduction of master trusts is part of a broader trend towards pension consolidation and is in line with the EU’s Institutions for Occupational Retirement Provision (IORP) II Directive, which aims to improve the governance and transparency of occupational pension schemes. Challenges in the Irish pension system Ireland’s pension system faces two challenges: rising occupational pension coverage and consolidating DC funds. Auto-enrolment is the main strategy employed to expand coverage, targeting about 800,000 workers without employer pensions, but its implementation has been delayed. With auto-enrolment on the horizon, master trusts are expected to manage more assets in the coming years, largely driven by regulatory changes. Initially, SMEs were the ones transitioning to master trusts, but as trust in this market strengthens, larger entities are also increasingly opting for master trusts. Consolidation is also progressing, driven by the IORP II Directive, which reduced the number of defined benefit (DB) schemes from 766 to 480 within a year. The industry goal to reduce group DC schemes to 500 or fewer indicates that about 12,000 schemes are yet to be consolidated. Age of retirement Along with these structural changes, the Irish pension market is increasingly integrating environmental, social and governance factors, driven by regulatory compliance and a desire to align with beneficiary values. Pension funds are updating policies, conducting ESG analyses, practising active stewardship and applying exclusionary screens. They are also investing in ESG assets, exploring impact investments, focusing on enhanced transparency and education, and participating in global initiatives like Principles for Responsible Investment (PRI). Despite these trends, Ireland continues to grapple with challenges arising from the absence of a legally mandated retirement age. This situation has led to issues such as a lack of clarity regarding retirement timing, inconsistent retirement ages in different companies (complicating the prediction of pension liabilities and funding), the potential for age-based discrimination and challenges for trustees managing delayed benefit payouts. In 2025 and beyond, Ireland's pension sector will likely be shaped by several key themes: Auto-enrolment rollout: From 30 September 2025, employers will be required to integrate auto-enrolment systems, which will require careful planning for compliance and a smooth transition. State pension sustainability: With demographic changes, there will be more focus on the financial sustainability of state pensions and retirement age policies, necessitating vigilance and flexibility. Flexible retirement: Employers and trustees must accommodate varying retirement preferences while adhering to regulations. DB scheme challenges: Financial pressures and solvency requirements for DB Schemes demand proactive risk management and member protection. Governance and investment strategies: Evolving market conditions and changes to the Standard Fund Threshold call for improved governance and investment strategies, with a growing emphasis on ESG factors. Digital resilience: Cybersecurity and data protection will become more critical, requiring ongoing investment in technology and strict operational standards. AI in pension administration: Artificial intelligence will bring process enhancements to pension administration but must be implemented with careful ethical and regulatory considerations to maintain trust and integrity. While these new trends in the Irish pension market address challenges arising from the lack of a statutory minimum retirement age, our perspective on Ireland’s pension system is that it currently stands at a critical juncture whereby: An ageing population necessitates reforms for better pension coverage and retiree adequacy; The shift from DB to DC schemes offers flexibility and improved risk management; Auto-enrolment pension schemes aim to boost participation and secure retirement for more workers; Master trust consolidation in Ireland indicates a move towards more efficient and professional pension management, driven by regulatory changes, cost pressures and a push for better governance; and Sustainable investing within pension funds showcases a commitment to ESG, aligning with responsible investing trends and mitigating ESG risks. Overall, these developments reflect a proactive approach to evolving market conditions and demographic shifts, aiming to ensure the sustainability and adequacy of retirement provisions for Irish citizens. Rav Vithaldas is Partner and Pensions Assurance Leader at EY Ireland 

In Irish news, the OECD has published the Economic Survey of Ireland 2025, and we issue a reminder that the deadline for submitting the 2024 Special Assignee Relief Programme employer return is 23 February 2025. In UK news, the UK Government has launched a consultation on e-invoicing and HMRC’s Making Tax Digital user research programme is seeking volunteers. In International news, the OECD is to publish a consolidated report on Amount B as part of the Two-Pillar solution on BEPS. Ireland 1. Read about the OECD’s recently published Economic Survey of Ireland 2025 and the key messages from the report. 2. We remind readers that the Special Assignee Relief Programme (SARP) employer return for 2024 is due for submission by 23 February 2025. UK 3. The UK Government has launched a consultation on e-invoicing which will run for twelve weeks. 4. HMRC’s Making Tax Digital programme is looking for volunteers to assist with user research. International 5. Read about the consolidated report to be published by the OECD on Amount B. 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.

From the Professional Accountancy team…… The Government has in recent days issued its Spring Legislative Programme 2025 the first since the new Government took office. In it there is some proposed legislation which may be of interest to members. Co-operatives The Co-operative Societies bill is listed for priority drafting. This legislation aims to place the co-operative model on a more favourable and clearer legal basis, thereby creating a level playing field with companies and encouraging the consideration of the co-operative model as an attractive formation option for entrepreneurs. Readers may recall that the previous Government in November 2022 approved the drafting of what was billed as ground-breaking legislation for the sector. The draft legislation proposes to repeal the Industrial and Provident Societies Acts 1893-2021 and provide a modern and effective legislative framework suitable for the diverse range of organisations using the co-operative model in Ireland. You can read more here by following the  link to the General Scheme of the Co-operative Societies Bill 2022. Readers can also go to the Institute’s technical hub pages where there is further information on this area. Other Also on the business regulation side, changes are proposed to the law on limited partnerships and business names. As we reported previously, heads of the general scheme for the Miscellaneous Provisions (Registration of Limited Partnerships and Business Names) Bill was published in July 2024  as both the limited partnership and business names legislation require updating to provide for modern business practices for those engaged in business using a business name or the limited partnership model .The Spring legislative programme indicates that work is ongoing on priority drafting of this legislation. Other legislation for priority publication is the National Cyber Security Bill to implement the Directive known as NIS 2 into Irish law. This directive was due to be transposed by 17 October 2024, so Ireland is overdue in its implementation. The previous government published heads of Bill of the National Cyber Security Bill in July 2024. Finally on this topic: - heads are in preparation for the Regulation of Artificial Intelligence Bill .The Bill will give full effect to the EU Regulation ,the Artificial Intelligence Act and will designate the National Competent Authorities responsible for implementing and enforcing the EU Regulation and will provide for penalties for non-compliance. - the Autumn 2024 legislative programme referenced heads in preparation and priority publication of the Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Bill. This was stated to amend the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (2010 Act) to ensure that Crypto Asset Service Providers are covered by national law in relation to Ireland’s Anti-Money Laundering and Terrorist Financing regime. Readers might note that in December 2024 the Minister for Justice by SI 724 of 2024 prescribed crypto asset service providers as designated persons under the 2010 Act. - the Finance (Provision of Access to Cash Infrastructure) Bill 2024 which was published by the Dept of Finance last year  has been restored to the Dail order paper . 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.    

Accountancy Europe has in recent months issued a factsheet entitled “Navigating the EU Anti-Money Laundering Regulation: Key Issues for the Accountancy Profession”.The factsheet highlights the key changes introduced by the new AML Regulation passed in Europe in 2024 and emphasises the importance of early preparation for these upcoming changes. Please click the link above to access the factsheet and here to preview the publication’s key insights on their website .

Revenue has recently updated three other Tax and Duty Manuals on the annual average exchange rates, licences for employees in private security, and charges on income for corporation tax. Details on these updates are set out below. The manual Annual Average Exchange rates includes the average market mid-closing rate relative to the euro, for the calendar year 2024. The manual Mandatory Licences for Employees in Private Security provides details to relevant taxpayers on claiming tax relief for the cost of a mandatory licence required for the performance of the taxpayers employment duties. The manual on Charges on Income for Corporation Tax purposes has been updated to include a new section dealing with the dissolution of companies.

Revenue has updated the Tax and Duty Manual Guidelines on PAYE Assessments to reflect Finance Act 2024. The manual has been updated to reflect the amendment introduced to the four-year time limit for making or amending PAYE assessments by a Revenue officer.  From 1 January 2025, the four-year limit commences at the end of the year following the year of assessment in which the employer return for that income tax month is made.

Revenue has updated the Tax and Duty Manual Small Benefit Exemption (SBE) to reflect Finance Act 2024. From 1 January 2025, the SBE has been updated to allow employers to give up to five qualifying incentives in a tax year to employees without incurring a charge to tax. To avail of the SBE, the cumulative annual value of the incentives cannot exceed €1,500. The manual includes details of the applicable limits in prior years on the total value and number of incentives which qualified for the exemption. Additional examples have also been included in the manual.

Revenue has issued a press release confirming that text messages claiming to come from them and which seek personal information from taxpayers are a scam. Revenue confirmed that they never request personal email through text, email or pop-up windows. Revenue advises that any emails or text messages which appear to be from Revenue and are suspected to be fraudulent or a scam should be deleted. Taxpayers should contact their local Revenue office to verify the status of any expected tax refunds. Individuals who have responded to these fraudulent emails or text messages and provided personal information are advised to contact their bank or credit card company immediately.

The annual Special Assignee Relief Programme (SARP) employer return for 2024 must be submitted to Revenue on or before 23 February 2025. The return should include details of all employees who availed of SARP relief for the period 1 January 2024 to 31 December 2024. Details on the filing of the return through Revenue’s online eSARP portal are available on Revenue’s SARP webpage.

The OECD Economic Survey of Ireland 2025 was launched last week at an event hosted by the Institute of International and European Affairs. The report notes that the domestic economy in Ireland remains robust primarily due to strong labour market performance. However, it notes that caution needs to be exercised when addressing spending pressures arising from an ageing population, infrastructure deficits, climate change and housing shortages. The key messages from the survey are as follows: Fiscal restraint is called for in the near term. At the same time, enhancing the fiscal framework, increasing spending efficiency and improving the medium-term resilience of tax revenues will be key to ensuring long-run fiscal sustainability. Preserving Ireland’s cost competitiveness requires a reduction in labour and skills shortages, lower legal costs and easing of the administrative burdens on businesses. Speedier implementation of plans and pricing emissions more uniformly across sectors is central to achieving Ireland’s ambitious climate targets. Policies to increase housing density, improve land use and development, raise productivity and lower costs in the construction sector are needed in order to boost housing supply. Commenting on the survey findings, Minister for Finance, Pascal Donohoe  said: “Our economy is in good shape and this gives us the resources and the bandwidth to address many issues. But continued economic success is not a given. The world is changing; the global economy is changing; our own economy is changing. It is incumbent upon us all – but especially those in the public sector – to prepare for these changes.”

Last September at the Labour Party Conference the Chancellor of the Exchequer announced that a consultation would be launched on electronic invoicing (e-invoicing). This consultation has now been launched and will run for 12 weeks until 7 May 2025. The Institute will be responding to this and will be engaging with members on this important issue. In the meantime, members can also email tax@charteredaccountants.ie with their views. The launch of this consultation was accompanied by a Press Release. The consultation process is accepting written responses by email or alternatively an online form can be completed. Anyone wishing to join the round table events on this consultation should email einvoicingengagement@hmrc.gov.uk. Chartered Accountants Ireland has already highlighted the significance of this change to HMRC. Ireland has been consulting on the modernisation of its VAT regime including e-invoicing which the Institute responded to in January this year highlighting the challenges that SME businesses in particular will face. In a broader context, should this proposal proceed in the UK, the timetable for its introduction will need to be very carefully considered as many SMEs are facing significant change in other areas of the UK tax system in the future; the payrolling of benefits in kind from April 2026 and the mandation of Making Tax Digital for income tax from the same date to name but two.