from the Professional Accountancy team ... The ‘28th regime’ a new EU legal framework for innovative companies is  a proposed legal framework that is additional to the national legal frameworks of the 27 Member States .It was referenced in the European Commission’s Competitiveness Compass of January 2025 and the European Commission's work programme of February 2025 .The idea behind it is that the EU will offer a parallel, elective legal framework that businesses can choose to operate under ,simplifying applicable rules and  bypassing the different national legal frameworks. In June 2025 the EU Commissioner for Justice Democracy and the Rule of Law ,Michael Mc Grath, appointed Dr Tom Courtney a solicitor ,leading author on Irish company law and previous chair of the Irish Company Law Review Group as his special adviser to advise him on the proposal for a new 28th regime company .Dr Courtney writes that this is a very important EU initiative to make it possible for companies to benefit from a simpler harmonised set of EU wide rules . 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.  

In this week’s post EU exit corner, we bring you the latest guidance updates and publications relevant in the post EU exit environment. The most recent Trader Support Service bulletin is also available as is the most recently published Brexit and Beyond newsletter from the Northern Ireland Assembly EU Affairs team. HMRC has also asked us to share that a new system will be implemented from 28 June 2025 to check specific customs declaration elements against the information contained in the relevant license. Implementation of CERTEX From 28 June 2025, CERTEX will be the new system used to check specific customs declaration elements against the information contained in the relevant license. HMRC has published detailed guidance on this. CERTEX replaces the Automatic Licence Verification System (ALVS) for Northern Ireland. This change does not impact express operators moving consumer parcels under the UK Carrier Scheme.      If a licence is required, this change will impact the following document types:  Certificates of Organic Conformity (COI), Plants and plant products (CHED.PP), Food and feed of non-animal origin (CHED.D),  Food and products of animal origin (CHED.P),  Live animals (CHED.A), Ozone Depleting Substances (ODS), and Fluorinated Gases (FGAS). For these licensed goods moving into or out of Northern Ireland by import, export or transit, information on declarations such as commodity code, net mass, and supplementary units must match with licences. This is essential to avoid unnecessary delays to the movement of goods.  Also, from 28 June 2025, the Common Health Entry Document (CHED) reference must also be provided on the declaration in the new format. The reference format must be letters followed by numbers and include the full stop character. For example, 'CHEDA.XI.2025.1234567'.   If a trader is pre-lodging a declaration that will be arrived from 28 June 2025 this will need to include the new CHED format. If they have already pre-lodged a declaration for arrival from 28 June 2025 using the old CHED format, they will need to use the Customs Declaration Service to amend this prior to the arrival of the goods. They must continue to use the old CHED format if they are pre-lodging a declaration that will arrive prior to 28 June 2025. Failure to use the correct CHED format will result in rejections once the goods arrive and potentially delays in getting the goods released. Processes for making a declaration or obtaining a licence remain unchanged.  For support for goods in movement, contact the Department of Agriculture and Rural Affairs (DAERA) on 0300 200 7852 or email daera.helpline@daera-ni.gov.uk. For general support with freight movements, traders can contact the Trader Support Service team, or call the HMRC Customs and International Trade helpline on‌‌‌ 0300‌‌‌ 322‌‌‌ 9434‌‌‌ (textphone 0300‌‌‌ 200‌‌‌ 3719).   For support with parcels movements, traders can contact their parcel express operator. Miscellaneous guidance updates and publications This week’s miscellaneous guidance updates and publications are as follows: Communications resources to help you move goods from Great Britain to Northern Ireland, Software developers providing customs declaration software, Simplified Process for Internal Market Movements (SPIMM): Category of goods guidance, Import goods to the UK temporarily, Software developers providing entry summary declaration support, Short shipments at temporary storage locations, Customs Declaration Service error codes, CDS Customs Clearance Request Completion Instructions for Inventory Exports, CDS BIRDS Declarations and Customs Clearance Request completion instructions, Notices made under The Customs (Import Duty) (EU Exit) Regulations 2018, Customs Declaration Completion Requirements for The Northern Ireland Protocol, Claim back an import security deposit or guarantee, CDS Declaration Completion Instructions for Final Supplementary Declarations, Simplified Process for Internal Market Movements (SPIMM) or UK Carrier (UKC) Scheme: Customs Declaration Service Data Element Completion Guide, CDS Declaration Completion Instructions for Exports, CDS Declaration Completion Instructions for Imports, Pipette tips (Tariff notice 12), Economic Operators Registration and Identification (EORI), and Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service.

The Executive Board of the International Monetary Fund (IMF) has concluded its annual review of the Irish economy. The publication issued by the IMF following the review acknowledges that the Irish economy has performed well and started 2025 in a strong position. In the report, the IMF noted that the Irish economy is projected to continue to grow but at a slower pace, with increased global uncertainty impacting on household and business spending decisions. The review also highlights significant downside risks to growth and public policy due to the concentration of activity in a small number of multinational enterprises and the impact of external trade and tax policy shifts on this cohort of businesses. Commenting on the report, Minister for Finance, Paschal Donohoe TD said: “I welcome today’s publication by the IMF, and its assessment that our economy and the impressive results we have achieved by building on our comparative advantages.  I note and share the IMF’s assessment of external risks, notably the reversal of globalisation, the ongoing disruption caused by regional conflicts, domestic capacity constraints, and the uncertainty in relation to corporation tax receipts. While I acknowledge Ireland’s vulnerability to the rise in global uncertainty, our economy has demonstrated resilience in the face of consecutive large shocks” Also commenting on the report, Minister for Public Expenditure, Infrastructure, Public Service Reform and Digitalisation, Jack Chambers TD said: “I welcome the IMF report which presents a timely opportunity to consider ongoing developments in our economy. Working with Minister Donohoe and his Department, we will be setting out how the country will manage government spending, taxes and reform over the next five years. This work looks beyond quick wins, ensuring informed investment, stability and real progress.”

Revenue has confirmed that their guidance on the Level 1 Compliance Programme – Debt Warehousing Scheme is obsolete as it is no longer possible to make a disclosure under the terms of the Debt Warehousing Scheme.  

Last week Chancellor Rachel Reeves delivered the 2025 Spending Review in Parliament which saw HMRC awarded an additional £0.5 billion in 2026/27 to make it a digital first organisation. The Spending Review sets planned spending totals for all UK Government departments from 2026/27 to 2028/29 inclusive in addition to investment spending plans until 2029/30. Although there were no specific tax announcements in the Spending Review, speculation now continues that there will be further tax rises in the Autumn Budget later this year given the spending and investment plans set out. The Institute for Fiscal Studies has now published a podcast setting out its analysis of the review whilst the Federation of Small Businesses says that the review lacked business focus. The House of Commons Treasury Committee subsequently announced an inquiry into the review. HMRC settlement The settlement includes additional funds of £0.5 billion in 2026/27 to “make HMRC a digital-first organisation”. This will be used to improve digital services and enable the use of AI to both assist taxpayers and improve productivity within HMRC.   Over the next three years, HMRC’s settlement is as follows: 2026/27: £7.3 billion, an increase from 2025/26 of £0.5 billion, 2027/28: £7.1billion, and 2028/29: £6.9 billion. By 2029/30:  90 percent of taxpayer interactions will be digital self-serve, up from the current 70 percent; and  HMRC will have reduced the number of letters it sends by 75 percent. HMRC will “eliminate all outbound post, with limited exceptions such as letters which generate revenue”.  However, it “will continue to ensure alternative channels, including phonelines, are still there for those who need them”.  The Institute looks forward to discussing how HMRC will achieve these very ambitious targets, including how inbound post will be treated, whilst also improving its current service levels as the taxpayer self-assessment population continues to grow because of fiscal drag. More information on this is expected to be available in the coming weeks when HMRC publishes its Digital Transformation Roadmap which was delayed from the spring pending the outcome of phase two of the 2025 Spending Review. The move to use more AI is interesting given recent comments by the Public Accounts Committee which said in a recent report that HMRC’s reliance on its legacy IT systems was restricting its use and development of AI. HMRC’s settlement also aims to enable the department to deliver the package of measures announced previously to close the tax gap including modernising HMRC’s use of data and recruiting an additional 5,500 compliance staff and 2,400 debt management staff.  Alongside the main Spending Review publications, HM Treasury also published ‘Spending Review 2025: Departmental Efficiency Plans’ which explains how different departments will deliver efficiencies. According to this, HMRC will deliver efficiencies of £773 million per year by 2028/29 in the following areas:  moving to digital services, improving and modernising its IT estate, continuous improvement and productivity which includes anticipated benefits from bringing the functions of the Valuation Office Agency within HMRC, restructuring its physical estate by consolidating offices into regional centres, exiting some sites and streamlining facilities contracts. By 2030, HMRC is aiming to have 85 percent of staff based outside London, and increasing focus on up-stream compliance to prevent errors from being made, rather than taking action after.

Revenue has issued a press release providing an update on the filing status of 2025 Residential Zoned Land Tax (RZLT) returns which confirms that approximately 1,800 returns for 2025 have been submitted to date, with close to €40 million in liabilities paid. The 2025 RZLT filing deadline was previously extended to 31 May 2025 to provide taxpayers with additional time to comply with the new registration and filing obligations. Site owners who qualify for an exemption or deferral from RZLT are still required to file a return to claim the relevant exemption or deferral. RZLT returns filed late are subject to surcharges, ranging from 10 percent to 30 percent of the annual RZLT liability. The applicable surcharge rate is based on the length of the filing delay.   In the press release, Revenue is urging site owners who are liable to RZLT and who have not yet filed a return, or not yet paid their RZLT liability to act promptly to avoid any further surcharges applying.

Last week, the Institute launched its position paper calling for the activation of powers to implement a reduced rate of corporation tax for Northern Ireland. In a time of global economic turbulence and increasing competition for foreign direct investment (FDI), Northern Ireland holds a unique position with dual access to both the UK and EU markets. However, the Institute’s view is that this perceived advantage is being undermined by a corporation tax rate that is currently double that of the Republic of Ireland. You can read the full press release here.

As the deadlines for reporting employee share transactions and benefits in kind approach next month, HMRC is holding a range of useful webinars for employers over the coming weeks. Trivial benefits Register for this webinar about trivial benefits which looks at: what a trivial benefit is, what conditions have to be met to be exempt from reporting to HMRC, examples of trivial benefits scenarios, what responsibilities employers have, and record keeping requirements. Social functions and parties Register for this webinar about social functions and parties, during which the following will be covered: the conditions for the event to be exempt from tax and national insurance contributions (NICs), what to do if it’s not exempt, and PAYE Settlement Agreements and how to apply. More information on PAYE Settlement Agreements is available on HMRC’s YouTube channel. Phones, internet and homeworking For information on phones, internet and homeworking, register for HMRC’s webinar which will provide an overview of the tax and NICs treatment where an employer: provides a mobile phone, reimburses the use of a personal mobile phone, provides broadband in an employee’s home, or pays towards it, and provides homeworking expenses to its employees. You can also view previously recorded webinars on a range of related employer areas.

Revenue has confirmed that,from 30 June 2025, agents will receive details of clients who have been issued with a demand notice or a final demand notice. The Institute, under the auspices of CCAB-I, has previously engaged with Revenue under the TALC Collections forum on this change.   Notifications will be generated to the agents ROS inbox on Monday mornings if a client has been issued with a demand notice in the previous week or if they are to receive a final demand notice that day. An agent may receive two separate notifications where relevant. Notifications will have a priority message flag, which will be highlighted by the gold star that appears in the last column on the right of the agent’s ROS inbox. The agent notification list will show details of the client(s), overdue taxes and the date of issue of the demand/final demand notice. Revenue has also provided information and relevant screenshots from ROS, which are available in this document ROS Agent Notification for Demand and Final Demand. 

In this week’s miscellaneous updates, The Treasury Committee has written to HMRC’s CEO about its handling of the recent loss of £47 million after taxpayer phishing scams, The High Court has held that VAT on private school fees is not a breach of children’s human rights, The Adam Smith Institute says that ‘Tax Freedom Day' was on 12 June this year and is coming later and later every year due to fiscal drag, The Government has announced that fuel payments for winter 2025/26 will be made to all pensioners. If income exceeds £35,000, HMRC will recover the full amount of the payment through PAYE or self-assessment. The position in relation to Northern Ireland will follow the same rules and was confirmed in an announcement from the Department for Communities,  The Government has provided information on the tax implications of employees selling shares on PISCES which we cover in more detail below, and 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 Check HMRC’s online services availability page for details of planned downtime and the online services affected. Tax implications of employees selling shares on PISCES In a recent Written Ministerial Statement (WMS) to Parliament, the Exchequer Secretary to the Treasury confirmed that the Government will legislate in the next Finance Bill to allow employers with employee permission to amend existing contracts to include a PISCES trading event as an exercisable event, without losing tax advantages under the various tax advantaged venture capital schemes. The WMS also confirms that more information on this will be published before the end of summer 2025. PISCES, the Private Intermittent Securities and Capital Exchange System, is a new type of secondary trading platform that will allow for the intermittent trading of private company shares. At the 2025  Spring Statement, the Government published a technical note explaining how such trading events will interact with the existing tax advantaged venture capital schemes and the tax implications for employees selling their shares on PISCES.

At a TALC Audit subcommittee meeting last week, Revenue indicated that the Central Register of the Beneficial Ownership of Trusts (CRBOT) team are visiting practitioners and those believed to be acting on behalf trusts. The purpose of the visits is to raise awareness of the obligations of trustees and the relevant CRBOT registration requirements.  

The OECD has published guidance to assist governments in the development of domestic manuals to guide  law enforcement authorities through each stage of a criminal tax investigation.