From the Professional Accountancy team…... In December 2025 the European Commission announced planned changes to the list of high-risk jurisdictions .Russia was added to the list in order to strengthen the international fight against financial crime. In addition, updates were also announced for the high-risk jurisdictions list following the decisions taken at the FATF and its list of ‘Jurisdictions under Increased Monitoring’ (‘grey list’), following the FATF Plenaries of June and October 2025. The EU has added new third-country jurisdictions to the list (Bolivia and the British Virgin Islands) and delisted a number of others (Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania). The changes will not enter into force until published in the Official Journal.  For further information regarding the planned changes to the list of high-risk jurisdictions, please refer to European Commission webpage on high risk third countries . 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.

Revenue has updated various pension manuals providing clarifications and guidance relating to the transfer of pension benefits, deemed distributions from pension funds and the taxation of retirement lump sums. The guidance on the transfer of payments has been updated to clarify the treatment of benefits transfer from an occupational pension scheme to a Personal Retirement Savings Account (PRSA), to another occupational pension scheme or to an approved buy-out bond (BOB). The guidance on funding and investments has been revised to update the reference to the Revenue pensions branch and to provide details on deemed distributions from pension funds. The guidance on the taxation of retirement lump sums has been reorganised to provide relevant information including 

Finance Act 2025 was signed into law on 23 December 2025. We will notify our readers once our TaxSource resource has been updated to reflect the relevant changes.

Revenue has published a new chapter in the pensions manual to provide guidance on the Automatic Enrolment Retirement Saving System. The guidance provides details on contributions to the auto enrolment system by participants, employers and the State, and includes relevant taxation implications and related contact details. The layout of the guidance is as follows: Paragraph 1: Introductory section, Paragraph 2: Contributions by participants and repayments of contributions to a participant, Paragraph 3: Contributions by an employer and repayments of contributions to an employer, Paragraph 4: Contributions made by the State, Paragraph 5: Taxation of payments made from the Automatic Enrolment Retirement Savings System, Paragraph 6: Taxation of payments made following the death of a participant, Paragraph 7: Interaction of the Standard Fund Threshold with auto-enrolment savings, and Paragraph 8: Contact details for the National Automatic Enrolment Retirement Savings Authority and the Department of Social Protection.

The deadline for the completion of the Large Corporates Division (LCD) VAT modernisation and eInvoicing survey is 5pm on 16 January 2026. We encourage members working in VAT-registered businesses under the remit of LCD and those advising LCD VAT-registered businesses to share their insights with Revenue and to urge their clients to complete the survey. While the survey includes a box for the taxpayer’s number, this does not need to be included to complete the survey, and you can leave this box blank and still respond. Further details regarding the survey are included in our earlier newsletter items.

Revenue has advised that ROS services will be unavailable today for an hour from 18.00 to 19.00 due to essential maintenance. This will impact public facing services for Local Property Tax, Revenue Online Service for businesses, vehicle registration and myAccount. Direct Payroll reporting and AIS/AES Customs services will not be impacted. 

The Department of Finance and the Department of Public Expenditure and Reform have published the Fiscal Monitor for December 2025 confirming an Exchequer surplus of €7.1 billion for 2025. This compares to a surplus of €12.8 billion recorded for 2024, with the year-on-year decline of €5.7 million being impacted by receipts arising from the Court of Justice of the European Union (CJEU) ruling in the Apple State Aid case. When these receipts are excluded from total receipts in 2024 and 2025, an underlying surplus of €3.8 billion was recorded which represents an improvement of €2.0 billion on the same period last year. Tax receipts collected for 2025 were €107.4 billion for the full year, which was €0.6 billion lower than in 2024. Excluding the once off receipts from the Court of Justice of the European Union (CJEU) judgement in the Apple State Aid case, total receipts amounted to €105.7 billion, an increase of €8.6 billion on the corresponding period in 2024. Income tax receipts for the month of December were €2.8 billion, unchanged compared to the same month in 2024. On a year-to-date basis, receipts for the full year of €36.6 billion were up by €1.5 billion (4.3 per cent), when compared to the full year 2024. Corporation tax receipts of €3.6 billion were collected in December, which is down by €0.5 billion on the same month in 2024. On a cumulative basis, receipts of €34.7 billion were down by €4.4 billion on 2024. When the once-off CJEU receipts are excluded, cumulative corporation tax receipts for the full year amounted to €32.9 billion, higher than the total for 2024 by €4.8 billion. December is a non-VAT due month and receipts of €0.5 billion were collected in the month with cumulative receipts recorded of €22.9 billion for 2025 which were ahead by €1.1 billion on the total receipts for 2024. Commenting on the figures, Tánaiste and Minister for Finance, Simon Harris said: “The Exchequer figures for 2025 are a reflection of the fundamental strength of our economy: income tax and VAT receipts, the clearest indicators of our economic performance, are continuing to perform well, while most other revenue streams are in line with expectations. As we look towards 2026, this Government is committed to using the resources of the State to improve people’s lives in a sustainable manner. Last month, we published Ireland’s Medium-Term Fiscal and Structural Plan, which represents a fundamental shift in the way we do budgetary policy in Ireland. The Plan fixes the level of spending without restricting us from improving public services, investing in infrastructure and protecting the public finances.”

Revenue has updated several guidance documents to reflect changes introduced by Finance Act 2025. We have listed below the documents which have been updated, and details of the relevant changes are included in the Institute’s Finance Bill at a glance document. In some cases, the examples in the guidance have also been updated to reflect the changes. Employer provided vehicles, Deduction for retrofitting expenditure, Rent a room relief, Charitable tax exemption, the updated guidance also provides further details on reliefs and exemptions for charities, and Universal Social charge, this updated guidance also confirms that employer contributions to the Auto Enrolment Retirement Savings System in respect of an employee are not considered relevant emoluments for the purposes of USC and that a donation under section 847AA TCA1997 in respect of donations to National Governing Bodies is not relieved from USC.

Over the break, Revenue has updated its Tax and Duty Manuals (TDMs) relating to Pillar Two which is the core guidance for companies to calculate taxes due under Pillar Two. The relevant manuals are TDM 01A-01-01A which provides guidance on the Pillar Two registration process and TDM 04A-01-02 which is the core guidance for companies calculation taxes under Pillar Two. In terms of registering for taxes under Pillar Two, companies should note that the deadline for registering has been extended to 28 February 2026 (previously 31 December 2025). Revenue guidance on Pillar Two Revenue has updated several areas of its guidance on Pillar Two. The changes include: Section 6.10, regarding the calculation of the Undertaxed Profit Rule (UTPR), has been updated for scenarios where there has been a merger. Section 8.9 has been updated to clarify the treatment of post-filing adjustments and tax rate changes. Section 9.8, regarding the Transitional Country-by-Country Reporting (CbCR) Safe Harbour, has been updated to clarify how a decrease in covered taxes affects the calculation of simplified covered taxes. Section 9.8.1 clarifies how the Transitional CbCR Safe Harbour applies where there is a change in tax residency of an in-scope entity. Section 10.2 discusses the impact of mergers and constituent entities joining and leaving in-scope groups. Section 11.5 clarifies the election to treat an investment entity as a tax transparent entity and the determination of the minimum tax rate applicable. Revenue has advised that the TDM will be updated further in due course to reflect the amendments made in Finance Act 2025. Revenue guidance on Pillar Two registration Revenue has also updated several sections of its guidance on registering for Pillar Two taxes. These include: A new paragraph explaining a new administrative practice for inactive or dormant entities that meet certain requirements. A new paragraph explaining an administrative practice where there is a dissolved entity. A paragraph explaining the registration process for entities without an active tax registration. Clarification on the ROS permissions required by agents using a ROS sub-user certificate. New guidance on approving agent link requests.

Revenue has issued guidance outlining the new stamp duty exemption on acquisitions of stocks and marketable securities provided for by Finance Act 2025. The note outlines the conditions applying to the exemption, details on making a valid notification and several illustrative examples. The exemption will apply to a transfer of relevant securities executed between 1 January 2026 and 31 December 2030, where the qualifying conditions are met. A transfer of relevant securities will qualify for the exemption where: At the date of execution of the transfer, the securities are admitted to trading on a regulated market or a multilateral trading facility within the EU, or on an equivalent third country market, the issuing entity’s closing market capitalisation was less than €1 billion on 1 December in the preceding year, and the transfer is executed during an exemption period, the start and end dates of which are determined by when a valid notification in respect of the market capitalisation was made to Revenue. Where securities are admitted to trading after 1 December of the previous year, the exemption may still apply if the issuer’s expected market capitalisation upon admission was under €1 billion.

Through our participation in the Tax Administration Liaison Committee (TALC), the Institute has consistently engaged with Revenue on the need to restructure the guidance on the reliefs for investments in corporate trades under Part 16 of the Taxes Consolidation Act (TCA) 1997, namely the Employment Investment Incentive Scheme (EIIS), the Start-up Capital Incentive (SCI) and the Start-up Relief for Entrepreneurs (SURE). We are therefore happy to share that Revenue has now restructured its guidance on these reliefs by expanding the guidance across four distinct documents. Part 16-00-02A now provides an overview of the reliefs and explains which of the other three documents is most relevant to the readers specific needs,be they a qualifying company, a qualifying investor, or an entrepreneur. Part 16-00-03 provides guidance for companies who may wish to raise risk finance using EIIS or SCI. Part 16-00-04 provides guidance for investors who seek to claim relief on investments made under EIIS or SCI. Part 16-00-05 provides guidance in relation to the income tax relief available for SURE. Readers should also be aware that the original guidance can be found here.

Last week, Revenue published preliminary results for 2025, including details of tax and duty collections, services delivered to customers, compliance timeliness, and outcomes from various compliance and enforcement initiatives. Most notably, in 2025 Revenue collected more than €106 billion in taxes and duties, along with over €34 billion collected on behalf of other government departments and agencies. In the press release accompanying the publication of the results, Revenue’s Chairman, Niall Cody, recognised the ongoing commitment of taxpayers and tax practitioners in meeting their obligations and achieving consistently strong, timely compliance rates with voluntary compliance delivering rates of 99 percent for large and medium cases and 92 percent across all other cases. The results show that Revenue completed 291,616 audit and compliance interventions during 2025 which yielded €734 million. A total of 189 tax avoidance cases were settled during the year resulting in an additional €41.7million collected on behalf of the public. Revenue is currently challenging 130 tax avoidance cases, relating to 27 transactions with 96 appeals ongoing. Readers should also be aware of the ongoing disclosure opportunity for worker arrangements which may need to have been reclassified following the Supreme Court decision in Karshan. The deadline for such disclosure is 30 January 2026 by which employers can regularise genuine cases of employee misclassification for 2024 and 2025 without incurring penalties or interest. Revenue has also advised taxpayers that 30 January 2026 is the closing date for the public consultation on the modernisation of withholding taxes, including Professional Services Withholding Tax, Relevant Contracts Tax, and expansion to the platform economy. Revenue has advised that you can complete the survey without inputting any identifying details simply by progressing to the next page. However, to the extent that you wish to engage with Revenue directly in the process, you may wish to include such identifying information.