The OECD has published a working paper which explores the relationship between the location of multinational enterprises (MNEs) global business functions and effective corporate taxation. The paper provides valuable insights into the structure of MNEs global value chains, as well as the real economic impacts of corporate taxation.

In this week’s miscellaneous updates, the minutes from the most recent meeting of the Joint Vat Consultative Committee, which Chartered Accountants Ireland is represented on, are available on GOV.UK. The most recent HMRC Agent Update is available as is the 19 December 2024 Stakeholder Digest which includes information on the appointment of the new HMRC CEO when the current CEO Sir Jim Harra retires in April 2025. A recent report from the National Audit Office (NAO) features suggestions to reduce the tax gap and HMRC has published an online tool to help workers or employment businesses using umbrella companies work out gross and net pay. HMRC has also recently launched new online services for platform operators to register and submit reports. VAT on private school fees applies from 1 January 2025 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 finally, check HMRC’s online services availability page for details of planned downtime and the online services affected. Latest Agent Update Agent Update: issue 126 is now available. Get the latest guidance and information including: the best way to pay voluntary National Insurance contributions, Simple Assessment, extended period for issuing tax calculation (P800) letters, The upcoming Self-Assessment deadline, and helping to test HMRC’s pay calculator for umbrella company workers. NAO report on the impact of fraud and error on public funds In this report the NAO suggests three ways to reduce the tax gap: HMRC should ensure that it understands the impact of its compliance work so that it can target activities to bring in the most tax revenue, HMRC should make it easier for taxpayers to comply and get help, so they pay the right amount of tax, and HMRC should ensure that tax rules are soundly designed and easy to comply with and evaluate and iterate rules as required. New online tool Last month HMRC collated their guidance, tools and documents for umbrella companies and those that use their services into a single page on GOV.UK. In addition, a new online tool designed to estimate gross and net pay from an umbrella company for a single role and the associated tax deductions was also published. Online services for platform operators Last month HMRC published a new online service to enable platform operators to register with HMRC. Note that even excluded operators who will not be submitting reports will still need to register with HMRC by Friday 31 January 2025. HMRC has also published a new service for platform operators to use to manage their digital platform reporting account after completing the registration process i.e. the service to be used for submitting reports and updating details. Both services are accessed via the Government Gateway ID.

The European Commission has published the annual VAT Gap in the EU Report, which measures the difference between expected VAT revenues and the amount actually collected. Most EU Member States have made significant progress in reducing the VAT compliance gap which was €89 billion in 2022, compared to €121 billion in 2018.

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 latest Brexit and Beyond newsletter from the Northern Ireland Assembly EU Affairs team. The Northern Ireland Affairs Committee has opened an inquiry into the operation of the Windsor Framework (WF) which is accepting evidence until the end of this month and HMRC has sent an email reminder that from 31‌‌‌ ‌‌January 2025 the next stage in the UK’s Border Target Operating Model commences when all European Union imports into Great Britain (GB) will require safety and security declarations. HMRC has also been writing to businesses which move non-qualifying Northern Ireland goods from Northern Ireland to GB to advise how this change will impact; more information on this is set out below. Moving non-qualifying Northern Ireland goods from Northern Ireland to Great Britain from 31 January 2025 From 31 January 2025, a business moving non-qualifying Northern Ireland goods will be required to submit an entry summary declaration prior to the goods arriving in GB  on the following routes:   Northern Ireland to GB, Northern Ireland to GB via Ireland, and European Union to GB via Northern Ireland The requirement for an entry summary declaration is in addition to the existing requirement for an import and export declaration for non-qualifying Northern Ireland goods moved from Northern Ireland to GB.  Which goods will require entry summary declarations?   There is no requirement for entry summary declarations for qualifying Northern Ireland goods, which will continue to benefit from unfettered access arrangements. Businesses can move qualifying goods directly from Northern Ireland to GB without customs or other controls, with extremely limited exceptions. This means the vast majority of goods moving from Northern Ireland to GB will not require entry summary declarations.  However, the following goods will require entry summary declarations from 31 January 2025: goods under a customs special procedure,  goods in authorised temporary storage,  goods which are moved from Northern Ireland and do not merely pass through Ireland before entering GB, and    goods indirectly exported from the European Union to GB via Northern Ireland which do not meet the definition of qualifying Northern Ireland goods when in Northern Ireland.   More information about qualifying Northern Ireland Goods can be found at https://www.gov.uk/guidance/moving-qualifying-goods-from-northern-ireland-to-the-rest-of-the-uk. More information on making an entry summary declaration is available at https://www.gov.uk/guidance/making-an-entry-summary-declaration. A business will need to discuss with their haulier or carrier to understand their plans for submitting the entry summary declaration on their behalf to ensure all parties are ready for this change. This may also include discussing whether there is any additional information they will need the business to provide in order to complete the declarations. The Trader Support Service will continue to submit the export declaration requirement for goods that require these when moved from Northern Ireland to GB.  It will also support the submission of entry summary declarations for non-qualifying Northern Ireland goods from 31 January 2025 when these are moved from Northern Ireland to GB and Northern Ireland to GB through Ireland.  Miscellaneous guidance updates and publications Moving goods between Great Britain and the UK Continental Shelf, Notice made under the Customs (Records) (EU Exit) Regulations 2019, List of customs training providers, Using similar goods to replace customs special procedure goods, Notices made under the Customs (Import Duty) (EU Exit) Regulations 2018, Notices made under the Taxation (Cross-border Trade) Act 2018, Notices made under the Customs (Export) (EU Exit) Regulations 2019, Pay less import duty and VAT when re-importing goods to the UK, Maritime ports and wharves location codes for Data Element 5/23 of the Customs Declaration Service, and External temporary storage facilities codes for Data Element 5/23 of the Customs Declaration Service.

The OECD/G20 Inclusive Framework on BEPS has published the Harmful Tax Practices – 2023 peer review reports on the exchange of information on tax rulings as part of the focus on improving transparency.

Last month, the Tax Administration EU Summit brought together the leaders of tax administrations from across the European Union to discuss their complex challenges. The event demonstrated the collective commitment of EU tax administrations to work together  to address common challenges.

The EU-Chile Interim Trade Agreement (ITA) will enter into force on 1 February 2025, replacing the previous EU-Chile Association Agreement. The ITA introduces a simpler approach to establishing preferential origin, allowing the use of self-certification based on statements on origin or importer’s knowledge.

Last month, the OECD released a pricing tool and fact sheets to facilitate the implementation of Amount B under Pillar Two. The purpose of Amount B is to provide for a simplified and streamlined approach to the application of the arm’s length principle to in-country baseline marketing and distribution activities, with a particular focus on the needs of low-capacity countries. The adoption of Amount B remains under consideration by OECD member countries.

Emma Broderick explains how suppliers of virtual events must account for VAT where customers are located, complicating compliance The EU VAT treatment of live streaming and virtual events services has changed with effect from 1 January 2025. Suppliers of such events will need to consider whether it will be necessary to account for VAT in multiple EU jurisdictions and how to efficiently manage any associated registration ‘footprint’. A virtual event isn’t defined in VAT law, but could include live-streamed events or other online events that involve people interacting in a virtual environment rather than meeting in a physical location.  The change is intended to apply VAT where the service is consumed, in line with the normal place of supply rules for business-to-business (B2B) services and similar rules for electronically supplied services provided on a business-to-consumer (B2C) basis. New measures Currently, VAT is levied on live-streamed events, including virtual events, where that event takes place. This means that live-streamed events are subject to VAT in the country in which the event is taking place, even if the viewers are located in a different jurisdiction. This is the case regardless of the business or non-business status of the customer. From 1 January 2025, EU law applies VAT to such events where the viewer, or customer, is located. This operates as follows: For B2B supplies, the EU business recipient may be required to self-account for reverse charge VAT in their EU country of establishment. For B2C supplies, the supplier will be responsible for collecting and remitting VAT in the EU country where the customer is located. This is intended to bring the VAT treatment of virtual events into alignment with that of other telecommunication, broadcasting and electronically supplied services (including streaming services or the delivery of other pre-recorded content). A pan-European €10,000 threshold applies for EU and NI businesses, and a nil threshold applies for non-EU established businesses. This change follows an amendment to the VAT place of supply rules for certain events services in Directive 2022/542. Irish law has not yet been amended to implement these changes, but we anticipate a statutory instrument to this effect will be issued in the coming weeks. Going forward The VAT treatment of events provided on a B2C basis will change considerably and bring about increased costs of compliance for businesses providing such B2C virtual services. The provider of the online events may need to register and charge VAT in each EU country where their final customers reside. Suppliers of live-streamed and virtual events will need to think about how to identify the location of their consumers and understand the impact of being subject to VAT in another EU jurisdiction. There is a VAT registration simplification available, known as the VAT One Stop Shop, to facilitate one single-EU-wide registration to remit output VAT on supplies, but there remains a challenge of monitoring differing VAT rates across the EU and pricing, contracting and invoicing decisions associated with this. The impact on cross-border B2B supplies should be less significant, as business customers should be able to self-assess for VAT on the reverse charge basis in their country of establishment, but suppliers will still need to consider invoicing and relevant VAT reporting requirements. Emma Broderick is a tax partner at Grant Thornton

As 2024 breaks temperature records, Derarca Dennis explores how businesses are advancing net zero strategies and why urgent climate action is essential In November, the EU climate monitor Copernicus reported that 2024 was "virtually certain" to be the hottest year on record, with warming above 1.5C, highlighting that the world was passing a "new milestone" in temperature records. These statistics, among countless others, highlight the critical need for immediate and sustained action to reduce emissions and mitigate the impacts of climate change. As the global climate crisis intensifies, the urgency for businesses to commit to and achieve net zero carbon emissions has never been more critical. The EY State of Sustainability 2024 report sheds light on the progress organisations are making towards sustainability. However, as events of recent weeks and months have shown us, every business, person and country need to do more. The global climate crisis is arguably the most pressing challenge of our time. Rising temperatures, extreme weather events and the degradation of natural ecosystems are just a few of the devastating impacts of climate change. A revision of National Defined Contributions (NDCs) is an absolute requirement as we know already that we will surpass 1.5C if we continue on current NDCs. As major contributors to global emissions, the actions businesses take to reduce their carbon footprint can have a profound impact on the overall trajectory of climate change. While part of a much bigger and very complex picture, by committing to net zero targets, businesses can help drive the systemic changes needed to transition to a low-carbon economy, protect natural resources and ensure a sustainable future for all. The EY State of Sustainability report shows that increased focus on sustainability is evident in the high rate of adoption of formal sustainability strategies among businesses. According to the report, 70 percent of respondents have approved and implemented a sustainability strategy, with the same number reporting alignment between that strategy and the overall business strategy. This alignment is crucial as it ensures that sustainability is integrated into the core operations and decision-making processes of the organisation. However, 35 percent of respondents feel their organisation is not doing enough, a notable rise from 17 percent in 2022. While it’s positive to see the overall trajectory of sustainability in business in Ireland moving in the right direction, it’s equally heartening to see that organisations are beginning to understand that there is much more to do. One of the most encouraging findings from the report is that 55 percent of organisations are aiming for net zero science-based targets, with 40 percent having established a clear roadmap towards achieving net zero. Leadership plays a crucial role in driving sustainability efforts, with 53 percent of organisations assigning C-suite responsibility for sustainability. In 67 percent of these cases, the CEO or managing director leads the initiative, while in 22 percent, the responsibility falls to the chief sustainability officer or head of sustainability. The assignment of sustainability responsibilities to senior leaders underscores the high priority businesses place on achieving their net zero targets. This commitment from the top is a clear signal to employees, customers and stakeholders of an organisation’s dedication to sustainability. And we need more leaders to follow suit to set the tone from the top if we, as a collective business community, are to play our part in halting the climate crisis. Why business emissions reductions matter Businesses are significant sources of greenhouse gas emissions, creating emissions through electricity and other energy use, manufacturing, transportation, agriculture and food waste, among others. By reducing their emissions, businesses can: Mitigate climate change: Lowering emissions helps to slow the rate of global warming, reducing the frequency and severity of climate-related disasters such as hurricanes, floods, and wildfires. Protect ecosystems: Reducing emissions can help preserve biodiversity and protect ecosystems that are vital for maintaining the planet's health and resilience. Drive innovation: The pursuit of net zero can spur innovation in clean technologies and sustainable practices, creating new business opportunities and driving economic growth. Enhance reputation: Companies that lead in sustainability can enhance their brand reputation, attract environmentally conscious consumers, and gain a competitive edge. Ensure regulatory compliance: As governments worldwide implement stricter environmental regulations, businesses that proactively reduce their emissions will be better positioned to comply with new laws and avoid penalties. The adoption of formal sustainability strategies, risk and materiality assessments, clear KPIs, and accountability, along with a strong commitment to science-based targets, are all essential steps towards achieving net zero. While there is more to do, it is very encouraging to see all the progress made in the past two years and great to see business leaders continuing to commit to building a better future for all. Derarca Dennis is Assurance Partner and Sustainability Services Lead at EY

When considering the trajectory of artificial intelligence, it’s worth looking back to see forward, writes Tania Kuklina Though it’s hard to believe now, following the invention of the World Wide Web in 1989, it took several years for businesses to realise its potential and value.   That journey began, slowly and tentatively, with ‘portals’ providing information for investors and the curious public. Next came sites assisting job applicants or helping customers to make purchasing decisions. With Web 2.0, businesses moved towards self-service models, enhancing customer engagement and user experience. In a clear case of back to the future, what we are currently witnessing in relation to artificial intelligence (AI) is similar, as businesses are only gradually beginning to understand its potential. Of course, it is already here and in a variety of guises. It provides enhanced search capabilities and supports learning and teaching. It can write, summarise and analyse large documents. In the realm of computer vision, AI is already being used for context-specific focus tracking in digital cameras. Despite these advancements, we are still waiting for AI’s first “killer app”, the groundbreaking application that will revolutionise and disrupt the world like the first internet browser on the World Wide Web.   We do not know if this application will be a job killer or a job creator, but what we do know is that, when it comes, it will shape the thinking of employers and employees about AI within their own organisations.   Productivity challenge At present, we believe AI will replace humans in low-stakes tasks. It is increasingly being used for customer engagement tasks, such as the pop-up web chat screens that sometimes launch when we visit websites. But as AI becomes more widespread and demystified, and the large language models that power them are cheaper to build, businesses are returning to a fundamental question – what is its value to them?   For businesses ready to look at their processes in a new way, the best way to assess AI’s value is the old-fashioned way – through business case assessment and return on investment.   Opportunities for improvement need to be quantified, processes may need to be redesigned and specific AI applications need to be developed. Total costs, including regulatory compliance, must be measured against potential benefits. People power People have a key role to play in assessing AI’s value proposition and making the technology work. As part of this work, several trends have emerged. First, workers still struggle with basic AI concepts and applications. Many do not grasp what AI implies for their roles, nor question why they should master a technology that might eventually take their jobs. This uncertainty underscores the need for clear communication and education about AI's personal benefits and potential. It is also increasingly clear that the success of generative AI (GenAI) technologies and the ability to realise their value depends on the ability of the workforce to adopt and apply them effectively. Despite this, many organisations are pushing for rapid adoption before their teams are fully equipped. As GenAI features evolve constantly, providing employees with consistent, stable and coherent learning experiences will prove difficult. With an ever-changing curriculum, Gen AI learning must be broad-based and continue to keep pace with change. Employees also need abundant structured opportunities to apply and practice what they are learning. Yet AI is not well enough democratised – not every employee has access to it, or support. This could lead to the ‘Matthew effect’, which is the phenomenon wherein those with pre-existing advantages accumulate more advantages over time. If access to GenAI is unevenly distributed, it could exacerbate existing disparities. AI has already started to extend our cognitive abilities, enabling us to access, understand and process more information than ever before. Highly skilled individuals find that when they explore and figure out how to use AI to support their work, it enhances and extends their capabilities without diminishing their hard-earned skills. However, for novices, an over-reliance on AI tools may limit their ability to develop essential skills such as problem-solving and subject matter expertise. So, while Gen AI requires traditional methods of evaluating investment and return on investment, in the training and people space, we need to reconsider learning approaches. This includes incorporating data-driven measurements such as tracking understanding and perceptions of GenAI, engagement levels and sustained versus lapsed adoption. KPMG has been actively developing and supporting these initiatives for clients, including through our GenAI Academy. Get it right, now Recognising the central role people play in the AI journey is crucial. It is also important to consider the medium and long-term impacts on skills, roles, learning, and culture. Investing in workforce upskilling is the cornerstone of how organisations show their commitment to putting humans at the centre of AI transformations. We may reach a point in the future where AI can be trusted to work autonomously. We may see a digital workforce of bots emerge as our co-workers. For now, however, AI adoption is a journey in which employee engagement, participation and support are vital. Tania Kuklina is a Director at KPMG

Chartered Accountants Ireland has agreed a 3-year strategic partnership with GRID Finance, Ireland’s leading independent lender for small and medium businesses. This partnership will deliver a biennial GRID Finance SME Business Sentiment Survey co-created with Chartered Accountants Ireland in support of its strategic focus on the SME/SMP sector. GRID will also become a sponsor of the Institute’s schools Bootcamp “Be The Boss” Challenge, a highly engaging, interactive business simulation for students signing up to the Bootcamp programme. This aligns with both GRID’s and the Institute’s ethos of educating future business leaders and promoting financial literacy from a young age, as well as giving back to the community. Finally, GRID will sponsor ‘Going into Practice’ days, an essential day of training for practitioners who are taking the first steps into running their own practice or being admitted as partners in small and medium sized practices in Ireland and Northern Ireland. Eoin Christian, CEO, GRID Finance, “We are thrilled to be part of this exciting new partnership between GRID Finance and Chartered Accountants Ireland. This collaboration marks a significant step forward in supporting and educating businesses of all shapes and sizes across Ireland by combining GRID Finance's innovative funding solutions with the trusted expertise of Chartered Accountants Ireland”. Barry Doyle, President Chartered Accountants Ireland, “This partnership is an excellent fit at an important time. As President, my commitment is to support and advocate for businesses, most particularly SMEs, the backbone of our economies. While the economy is performing strongly, businesses are facing turbulence, none more so than SMEs. “By virtue of their size, they often lack the ability to remain resilient against external shocks, of which there is potential in the global economy this year. Our partnership with GRID will allow us to map SME sentiment, understand and respond to it, while also investing in the education of our future business leaders and promoting financial literacy.” About GRID Finance GRID was founded in 2013 with a belief and a passion. Our belief is that small and medium sized businesses are the economy’s real powerhouses. And since they are so important, we’re passionate about keeping them open for business. GRID’s total focus is on providing quick and easy access to the capital, advice and tools small businesses need to grow and thrive.