Earlier today HMRC advised us that some of its telephone helplines are currently experiencing a reduced level of service due to a technical issue. HMRC first made us aware of this late last week. HMRC is working urgently to resolve this. Taxpayers and agents can continue to use online services, where relevant, which we have been advised are working as normal.

COP29 concluded in late November with uneasy agreement on the controversial Baku Finance Goal pledging $300 billion in climate funding to developing countries, writes Susan Rossney COP29, the global climate summit, concluded in the early hours of 24 November in Baku, Azerbaijan. There were some positive developments, such as the deal reached on Article 6 of the Paris Agreement to finally allow countries to trade carbon credits with each other. Most significantly, though, for this ‘climate COP’, was the final agreement called the Baku Finance Goal. In 2009, at COP15 in Copenhagen, parties agreed a collective goal for developed nations to provide $100 billion annually in climate financing to developing countries. The new goal agreed at COP29 ups the annual financial target to $300 billion, to be funded from public sources, with provision for the shortfall to be made up of funding from private sources. To say opinion was divided on this new goal is an understatement. While some parties are cautiously optimistic that the agreement would at least keep the core principles of the Paris Agreement alive, many more were outraged by how much the new goal falls short of what is actually needed. It is generally agreed that $1 trillion per year by 2030 (rising to $1.3tn per year by 2035) is needed to help developing countries build resilience, prepare for disasters and cut emissions of planet-warming greenhouse gases. While this figure is enormous, it’s worth noting for context that $2.4 trillion was spent on weapons in 2023, and at least $1 trillion was spent in 2022 on subsidies to keep fossil fuel prices artificially low. Also worth noting is that the provision of financial support to developing countries for climate action serves both a moral and economic purpose for wealthier countries. The chaos caused by the climate and biodiversity crises to societies and economies is not limited to developing countries alone. This was demonstrated most recently by the 224 lives lost in Spain as a result of flooding linked to rising temperatures in the Mediterranean Sea. On 28 November, Spain’s government approved a new “paid climate leave” entitlement of up to four days to allow workers take time off if unable to travel to their place of work in the event of official warnings of extreme weather conditions. The Institute for Economics and Peace further predicts that one billion people face being displaced within 30 years due to the climate crisis, with huge impacts for both the developed and developing worlds. COP30 will take place in Belém, Brazil in 2025. Its focus will centre on efforts by each country to reduce national emissions and adapt to the impacts of climate change (the so-called ‘NDCs’ or ‘nationally determined contributions’). It remains to be seen if COP30 will achieve what G20 leaders have said it should – i.e. to be “our last chance to avoid an irreversible rupture in the climate system”. Susan Rossney is Sustainability Advocacy Manager at Chartered Accountants Ireland. Check out Chartered Accountants Ireland’s sustainability centre for signposts to a variety of resources available to businesses. Also, subscribe to the Institute’s fortnightly Technical Round Up and weekly Sustainability/ESG Bulletins, both in the weekly Chartered Accountants Ireland newsletter, and on LinkedIn.

Comments from Chartered Accountants Ireland were included in a recent Sunday Independent article on the operation of benefit-in-kind on staff benefits. The Institute’s Head of Tax, Gearóid O’Sullivan was recently featured in the Sunday Independent answering readers’ questions on the rent tax credit and dividing land that is jointly owned.

Revenue has published the following new VAT manuals:  VAT notes for guidance following Finance Act 2024, and VAT treatment of share transactions and trading platforms. In addition, the following manuals have also been updated:  VAT Treatment of Factoring and Invoice Discounting, VAT and Solicitors includes a new paragraph (4) on legal fees relating to lenders, and VAT treatment of stock exchange fees has been updated to provide guidance on the current regime.

Section 125A SDCA 1999 provides for a stamp duty to be levied on certain health insurance contracts entered into between health insurers and their customers. Revenue has updated the Stamp Duty Manual which provides guidance on the levy on authorised insurers. The updated manual now includes the rates of the levy for accounting periods commencing on or after 1 April 2025, as provided for by section 10 of the Health Insurance (Amendment) and Health (Provision of Menopause Products) Act 2024, which was enacted on 11 November 2024.  The following stamp duty manuals have also been updated to reflect amendments to Part 9 SDCA 1999 contained in Finance Act 2024:  Part 9: Levies Part 9 - Section 126AB - Further levy on certain financial institutions

Revenue has published a new Tax and Duty Manual which provides guidance on obtaining a corporation tax deduction for stock exchange listing expenditure. With effect from 1 January 2025, new section 81D TCA 1997 provides corporation tax relief for expenditure of up to €1 million incurred by a company on listing its shares for the first time on an EEA stock exchange. According to the manual, the admission to trading of the company’s shares must take place on or after 1 January 2025 and on or before 31 December 2029.   

Revenue has updated the Tax and Duty Manual which provides guidance on pre-letting expenditure in respect of vacant residential premises. The updated manual now reflects the extension to 31 December 2027 for the deduction of expenses incurred on a vacant residential property against rental income from those premises under section 97A(2) TCA 1997.  

The Central Statistics Office (CSO) has published the Quarterly National Accounts for the third quarter of 2024. Modified Domestic Demand increased by 1.3 percent relative to the previous quarter and was up 4.1 percent on an annual basis. Gross domestic product (GDP) grew by 3.5 percent in Q3 2024 and increased by 2.9 percent on an annual basis.  Commenting on the figures, the Minister for Finance, Jack Chambers TD, said: “I am pleased to see continued strength in the domestic economy in the third quarter of 2024. Modified Domestic Demand – my preferred metric of Ireland’s economic performance – grew by 1.3 per cent on a quarterly basis and recorded strong annual growth of over 4 per cent. Importantly, growth on an annual basis has been broad based in nature with both consumer spending (1.7 per cent) and modified investment (10.4 per cent) making a positive contribution. This solid growth is consistent with the strength of our labour market and the robust exchequer figures released yesterday. Taken together these metrics all demonstrate that the economy has performed strongly this year. While today’s figures are encouraging they are, of course, backward looking. Indeed, the economic outlook has become increasingly uncertain and risks are now clearly titled to the downside with the most pressing risks external in nature. As a small, open and highly globalised economy, Ireland is particularly vulnerable to any deterioration in the external environment.  Put simply, these are risks that we cannot control directly – we must instead focus on managing what is in our control. In particular, we must continue to build up our fiscal buffers, invest in our people and our infrastructure, and ensure the economy remains competitive. This will help ensure that we are in the best position possible to address future challenges.” 

With November being the most important month of the year for tax receipts, the Minister for Finance noted that the recent November Exchequer figures indicate that tax revenues continue to perform well. November is the month in which the largest payments are made for corporation tax, as well as the last VAT-due month of the year. Total tax receipts for November amounted to €22.8 billion, €7.2 billion (or 46.1 percent) higher than November 2023.   November is also the deadline for self-assessed income tax. Income tax receipts in November were €4.7 billion, only €60 million (or 1.3 percent) ahead of November last year. However, this relatively weak performance year-on-year was offset by continued growth in PAYE receipts. Overall, income tax receipts were €1.9 billion, or 6.4 percent, ahead of November 2023.   Corporation tax receipts in November amounted to €13.7 billion, which is €7.4 billion (or 116.8 percent) higher than November last year. The bulk of the increase is due to receipts arising from the Apple tax case ruling in September. On a cumulative basis, corporation tax receipts of €35.0 billion are now ahead of last year by €13.0 billion (or 59.1 percent).  VAT receipts to end-November are €3.1 billion, 1.3 billion (or 6.4 percent) up on the same period last year. The Exchequer surplus stood at €13.8 billion, to end-November, an increase of €8.4 billion in comparison with the same period last year, reflecting the Apple tax case revenues received in November. Commenting on the figures, the Minister for Finance, Jack Chambers TD, said:  “The Exchequer returns to end-November show most tax heads have demonstrated steady growth across the year. The growth in income tax and VAT receipts demonstrates the strength of our economy and labour market, but our public finances remain exposed to highly volatile corporation tax receipts. This revenue stream is also skewed by the receipt of around two-thirds of the revenue arising from the CJEU ruling of September 10th.”   

Amendments to FRS 102: are you ready for change? Aimed at improving financial reporting practices, the latest FRS 102 amendments introduce important changes finance teams must begin preparing for today. Emer Fitzpatrick and Cayetano Bautista III delve into the details. FRS 102 is the predominant accounting standard used by small and medium businesses (SMEs) and private family businesses across the island of Ireland. It was introduced in 2013, applying to accounting periods commencing on or after 1 January 2015, with early adoption permitted. The UK Financial Reporting Council (FRC) is the standard setter for FRS 102 and performs periodic reviews of the accounting standard, at least every five years. The aim of these reviews is to take account of changes in global accounting standards – such as changes to the International Accounting Standards Board (IASB) accounting standards, and to respond to specific issues as they arise, such as regulatory decisions and stakeholder feedback. Amendments are then developed and proposed after feedback has been sought from the relevant stakeholders. The first periodic review of FRS 102 was completed in December 2017, coming into effect on 1 January 2019, and the FRC recently completed another periodic review in March 2024. This most recent review has taken several years to complete due to the need for extensive consultations with stakeholders. The effective date of the amendments arising from this review will be applicable for accounting periods on or after 1 January 2026. (Earlier effective dates apply to new disclosures about supplier finance arrangements, starting from 1 January 2025, with early application permitted). Early application is, however, permitted where all amendments are applied simultaneously. So, what are the key amendments arising from this review, and how can you prepare for these changes? FRS 102 review: key amendments Single lease accounting approach for lessees (Section 20) Under the current model, lessees classify leases as either finance or operating, depending on whether the lease transfers substantially all the risks and rewards of ownership from the lessor to the lessee. This approach is similar to the model used under old Irish Generally Accepted Accounting Principles (GAAP) and IAS 17 – “Leases”. The FRS 102 amendments will largely align Section 20 with IFRS 16 – “Leases”, eliminating the distinction between finance and operating leases for lessees. This will require lessees to recognise right-of-use assets (ROU) and lease liabilities on the Statement of Financial Position (SOFP) for all leases, apart from short-term leases and low-value assets. Subsequently, the ROU is depreciated over the lease term on a straight-line basis, while the lease liabilities are amortised using the effective interest method, which results in a frontloading of the lease expense, reflecting the underlying financing nature of leases. Let’s illustrate this with an example. Lease term   3 years  Annual payment payable at the end of the year  €50,000  Discount rate (annual)  5% SOFP – lease commencement (rounded to the nearest €000)   ROU / lease liability   €136,000*   *The initial ROU/lease liability is for illustrative purposes only. These should be calculated using the following formula: Present value (PV) of lease payments not paid at that date and discounted using the appropriate discount rate. [PV of €50,000 × 3 years at 5%] In most cases, the ROU and lease liability will be equal to each other on the inception of the lease. Statement of Comprehensive Income (SOCI) – Year 1   ROU depreciation (operating profit)  €45,333 [€136,000 ÷ 3]  Interest on lease liability (finance cost)  €6,800 [€136,000 × 5%] SOFP – Year -1    ROU   €90,667 [€136,000 – €45,333]  Lease liability  €92,800 [€136,000 – €50,000 + €6,800] The amendments provide guidance on what constitutes a lease, how to determine the lease term, how to account for modifications and remeasurements and other practical expedients. It is important not to underestimate the complexity of this new lease model. Consideration must be given to several factors, such as whether an arrangement meets the definition of a lease and how to calculate an appropriate discount rate for every lease. Five-step revenue recognition model (Section 23) The FRS 102 amendments also introduce a comprehensive five-step model for revenue recognition aligning Section 23 of FRS 102 with IFRS 15 – “Revenue from contracts with customers.” The five steps are as follows: Identify the contract(s) with a customer. Identify the performance obligations in the contract. Determine the transaction price. Allocate the transaction price to the performance obligations in the contract. Recognise revenue when (or as) the entity satisfies a performance obligation. The core principle is to align revenue recognition with the transfer of control of goods or services to customers which may either be over time or at a point in time. This also aligns revenue recognition with the contractual terms in relation to the enforceable rights and obligations of the customer and supplier. The five-step model aims to address the challenges in accounting for bundled goods and services by introducing the concept of allocating the consideration from the customer to the separate and distinct performance obligations, representing the promised goods or services within the contract. The amendments also provide guidance on several topics, such as combining two or more contracts entered into, at or near the same time with the same customers, contract modifications and some practical expedients. It is important to note that the new five-step revenue recognition model could alter the timing of revenue recognition, especially for complex contracts with bundled goods and variable consideration. Other important amendments to note The amendments to FRS 102 also contain several incremental improvements and clarifications including, but not limited to, the following: IAS 39 option removal: Entities not already applying IAS 39 recognition and measurement principles for financial instruments can no longer adopt such policies under Section 11 and 12 of FRS 102. Supplier financing: Section 7 of FRS 102 will now require additional disclosures about supplier finance arrangements and their impact on SOFP and cash flows. Fair Value measurement: A new Section 2A (Fair Value Measurement) replaces the Appendix to Section 2 of FRS 102, incorporating the principles of IFRS 13 – “Fair value measurement.” Going concern disclosures: Section 3 of FRS 102 has new requirements for management to affirm consideration of future information and to disclose significant judgments on going concerns. Business combinations: Section 19 of FRS 102 has been updated to include guidance on the identification of an acquirer in a business combination similar to the principles of IFRS 3 – “Business combinations.” Share based payments (SBP): Section 26 of FRS 102 includes enhanced guidance on accounting for vesting conditions, fair value determination and SBPs with cash alternatives. Uncertain tax treatments: Section 29 of FRS 102 includes guidance for uncertain tax treatments, which aligns with IFRIC 23 – “Uncertainty over Income Tax Treatments” principles. FRS 102 amendments: next steps We have outlined some practical steps you can take to help prepare for these changes. Assess the impact on your financial statements and business metrics As discussed above, the changes to Leases and Revenue may have a significant impact on financial statements (FS). The new lease accounting model may affect your company’s financial metrics or key performance indicators (KPIs) such as EBITDA, net profit and net debt, to name a few. Not only will the changes to KPIs have an impact on the FS but they may also impact your lending arrangements or covenants. For the new revenue model, consideration must be given to how any potential changes to the timing of revenue recognition may impact both reported and forecasted revenue and profits. You will also need to consider how the other amendments listed above will impact the FS and whether you have the necessary in-house expertise on your finance team to carry out the work required to comply with these amendments. Increased disclosure will be required in the notes to the FS, and this may include some new and previously undisclosed information. Understanding these requirements will help guide your accounting processes and the preparation of the FS. Being well-prepared will ensure compliance and transparency in your financial reporting. Consider whether operational changes are required The new lease accounting and revenue recognition models are closely tied to contractual terms and conditions. This will require additional information and financial modelling from contracts. An early assessment of your current accounting processes, systems and controls is essential to identify the necessary operational changes. Other considerations, such as the number of lease agreements and revenue contracts a company may have, will determine the amount of work involved, especially with regard to preparing an amortisation table and the potential need for external valuation expertise to determine an appropriate discount rate for every lease agreement. Determine the best game plan for the transition It is critical to ensure that your finance team is ready for these changes. Engaging your finance team through training courses, workshops and other methods – before and during the transition phase – will be important in ensuring your team fully understands the upcoming changes. Preparing for change: act now The aim of these FRS 102 amendments is to improve financial reporting by aligning FRS 102 more closely with IFRS. Although most of the amendments will not take effect until 2026, early application is allowed if all amendments are adopted simultaneously. Thus, it is critical that companies put a game plan in place today to determine the optimal timing, scope and method for adopting the FRS 102 amendments. The time to act is now. Emer Fitzpatrick is a Senior Manager in PwC Corporate Reporting Services and a member of the Financial Reporting Technical Committee of Chartered Accountants Ireland. Cayetano Bautista III is a Senior Manager in PwC Capital Markets and Accounting Advisory Services.

Ongoing turmoil in Europe’s largest economy will be exacerbated by Donald Trump’s pledged import tariffs, highlighting the need for EU countries to pull together to withstand transatlantic  trade disruption, writes Judy Dempsey Pity Germany’s next government. Olaf Scholz’s successor will have no time to lose when the federal elections end on 25 February 2025, bringing Scholz’s bickering coalition to a close.  Now, the economy is the priority. Germany’s outgoing government believed the old industrial model just needed a bit of tinkering to effectively counter China’s ever-increasing economic presence – but those days are over.  Massive job cuts announced by Volkswagen and ThyssenKrupp (the traditional giants of the car and steel industry, respectively) demonstrate how this government and its predecessor, led by Angela Merkel, failed to prepare for the inevitable impact of de-industrialisation. The replacement of the combustible engine with electric alternatives – which China has rapidly embraced – has been a shock for German industry, which had mistakenly earmarked China as a reliable export market.  No more.  Germany’s high energy costs and fierce competition from Beijing have combined to catalyse the failure of Germany’s old industrial model – so Berlin’s next government must hit the ground running.  This means making the transition from an old industrial base to more modern sectors driven by digital culture.  It means grappling with a demographic crisis that will only cost more unless the government introduces a robust immigration policy to address the huge labour shortages affecting most sectors.  None of this will happen unless Germany’s next leader loosens the ‘debt brake’ constitutionally limiting government spending.  Germany is in dire need of public financing if it is to invest in defence, climate adaptation, security, housing, transport health and education.   The debt brake (and overbearing bureaucracy) has starved investment. The government already has a spending gap of €64 billion for 2025. If, between 2025 and 2030, defence spending targets were to rise from two to three percent of GDP, it would cost another €300 billion.  This German malaise has serious consequences for Europe.  Last year, Germany had the highest level of intra-EU trade, contributing to 21 percent of the European Union’s exports of goods to other countries. What happens in the EU’s largest economy impacts the entire bloc. To make matters worse for Germany’s next Chancellor – and for the EU – is US President-elect Donald Trump’s stated intention to impose a 10 percent tariff on goods imported from Europe and 60 percent on goods from China.  Germany’s export-driven car industry, one of Trump’s targets, is particularly vulnerable and speeding up the manufacturing of electric-driven vehicles would only solve part of the problem. To escape tariffs, it is reasonable to expect the car industry to move manufacturing to the US. This is exactly what Trump wants.  However, back in Germany, the dwindling market in China for German cars could lead to further job losses.  Trump, too, will pile the pressure on Berlin and NATO allies to spend more on defence. It won’t be easy. Not only because of the costs involved but also because Germany’s far-right and far-left parties are opposed to NATO, opposed to supporting Ukraine and generally pro-Russia. All in all, Germany’s ability to deal with its finances, defence and investment issues will be complicated by the Trump administration.  Ultimately, EU countries need to pull together – even integrate – to withstand the pressures on the transatlantic relationship. Judy Dempsey is Nonresident Senior Fellow at Carnegie Europe *Disclaimer: The views expressed in this column published in the December 2024/January 2025 issue of Accountancy Ireland are the author’s own. The views of contributors to Accountancy Ireland may differ from official Institute policies and do not reflect the views of Chartered Accountants Ireland, its Council, its committees, or the editor.

Smaller employers completing gender pay gap reports for the first time in 2025 have a wealth of information to draw on but much work ahead, write Aoife Newton and Andrew Egan A lot can be learned from the first three years of gender pay gap reporting in Ireland, which means those employers new to this reporting in 2025 have a wealth of valuable data to learn from.  Many large employers are already producing in-depth and illustrative annual gender pay gap reports. Although primarily focused on statutory reporting requirements, they also reflect best practice approaches to tackling gender pay gaps and outline clear, insightful ways to explain these gaps.  For employers preparing to report for the first time, these reports are worth reading, if only to give you a sense of the approach others have already taken. As much as you can learn from this, however, you should not underestimate the volume of HR, payroll and other data required for gender pay gap reporting, the complexity involved in merging this data, the calculations required and the scrutiny you can expect to face when communicating your findings to stakeholders internally and externally.  Gender pay gap results published in 2025 will be based on data collected over 12 months, typically from July 2024 to June 2025, though the exact dates will depend on each employer’s chosen snapshot date.  This means employers not already focusing on gender representation across their organisation may find themselves having to explain sizable gender pay gaps. With Irish employers employing as little as 50 people in scope for reporting next year, we expect to see a lot more focus on this area from the media, employees and other stakeholders.  Smaller employers are subject to the same legislative requirements as their larger counterparts; there are no exemptions for employers with limited resources. This means they will be required to produce a report reflecting accurate results aligned with 11 statistical gender pay gap metrics along with a narrative detailing the reasons for existing gaps and measures (both existing and planned) to reduce or eliminate these gaps.  New 2024 regulations – new results? The Employment Equality Act 1998 (section 20A) (Gender Pay Gap Information) (Amendment) Regulations 2024 were introduced last May and it will be interesting to see what impact they have on this year’s gender pay gap reporting results. Under the 2024 Regulations, social welfare payments relating to certain periods of protective leave can now be included in gender pay gap calculations. This is a welcome development as it may help reflect parity of payment in line with notional hours worked.  Prior to this, the regulations have only included ‘top-up’ payment made by employers as relevant pay for gender pay calculations, providing that social welfare payments should be excluded (notwithstanding that full hours have been included).  The impact of this approach has been to reflect a lower hourly rate of pay for employees in receipt of certain welfare payments.  For 2024 reporting and beyond, employers will need to include both maternity leave benefit along with a maternity ‘top-up’ payment (i.e. 100% pay) matched with 100 percent hours.  This should reflect a notional increase in pay for women, thus helping to ‘reduce’ an employer’s gender pay gap compared to last year’s reporting. The 2024 Regulations also adjust the treatment of share options and interests in shares. These are now considered benefit-in-kind rather than forming part of bonus payments.   This could have a significant impact on the gender pay results of in-scope employers as benefit-in-kind is not included in either overall gender pay calculations or separate bonus calculations. Previously, share options and interests in shares were included in both.   The issue of actual shares (to be valued on the date of issue) continue to be part of the bonus calculation. So far in 2024, we are seeing steady results in completed reports compared to reports in the two years prior.  Typically, any significant variations in results can be explained by reference to changes in personnel at a senior level or due to business restructures. Both will continue to impact annual reporting.  Comparison is key An important aspect of reporting for many employers is how favourably, or otherwise, they compare with their peers operating in the same sector or industry. For example, if an employer operates in a sector that is traditionally male dominated (e.g. engineering), this will clearly influence their gender pay gap results.  In certain sectors, such as professional services, where employers are recruiting in the same talent pool as their competitors, how their organisation compares to their peers really matters.  Ideally, employers will want to see results that are either “similar to” or “more favourable than” their competitors.  If their results are not, boards and management should query why they are out of line with competitors with a similar resourcing structure recruiting from the same talent pool. In particular, it is worth examining whether there are discriminatory practices behind any results revealing a wide gender pay gap as this could be affecting female representation at the higher levels of the organisation – or perhaps the organisation’s pay and bonus structure is weighted in favour of men?  Ultimately, gender pay gap results serve to root out any embedded issues that may be impeding more equitable pay across the board. New developments in 2025 The biggest change in 2025 will be the extension of the gender pay gap reporting obligation to employers with just 50 employees. In addition to this development, we expect to see some changes to how the gender pay gap reporting process is carried out.  As it stands, employers must include their gender pay gap data and statement of information on their website – or have it available for public inspection.  We understand the Government has issued a tender for the development of an online gender pay gap portal, with development due to start in the coming weeks and testing earmarked for the new year.  It is expected that the portal will have similar functionality to an online gender pay gap portal already in operation in the UK.  If this is the case, the portal will allow employers and other interested parties to compare and contrast results with ease, rather than having to rely on the current, more laborious, manual process.  This new system of reporting is also expected to result in the reporting deadline being brought forward to the end of November 2025.  Employers – both those already reporting and new to the regime – will therefore have a five-month window in which to report, slightly shorter than the current six-month timeframe.  All employers in scope for reporting next year must thus be vigilant and ensure they are up to date at all times with the portal requirements and potential new deadline.  The EU Pay Transparency Directive Looking further ahead, as the EU Pay Transparency Directive (the Directive) is due to be transposed by June 2026, we expect to see many more changes to the reporting regime in the coming years.  The implementation of the new rules under the Directive will not only change the amount of data required but will also align gender pay gap reporting more closely with the employee engagement agenda.   Further, gender pay gap reporting under this Directive will not simply be about producing an annual report of results and narrative; it could also open up data results to scrutiny from trade unions and other employee representatives.  Where there are gaps of more than five percent in any category of worker (these categories are yet to be defined), which cannot be objectively justified and cannot be rectified within a six-month period, the employer may have to engage in a joint pay assessment.  Such joint pay assessments are expected to involve trade unions or other employee representatives.  Employers and all relevant stakeholders should, therefore, be more concerned about how the Directive will shine a light on their organisation’s gender pay gaps, bringing current reporting closer to the principle of equal pay and overall pay transparency.   Acknowledge the gaps Given the additional layer of data scrutiny under the EU Pay Transparency Directive, we are encouraging all employers with gender pay gaps in favour of male employees to commit to deeper analysis.  By better understanding the causes of such gaps at every level of their business, they will find these discrepancies easier to explain (based on objective criteria), and also potentially easier to rectify.  And while not all gaps may be fixable in the short-term, a deep analysis can give employers a good starting point to devise a longer-term solution, as well as greater scope to explain these gaps to legislators with reference to objective criteria. Ultimately, employers who are not focused on gender parity, closing gaps or preparing for the impending new regime, may be exposed to time-consuming and potentially contentious joint pay assessments.  Aoife Newton is Head of Employment and Immigration Law, KPMG Law LLP  Andrew Egan is a Director with KPMG, leading the firm’s tax data and analytics service offering