Revenue has published a further warning of fraudulent emails, SMS (text messages) and phone calls seeking personal information from taxpayers. Revenue has updated its website to highlight recent fraudulent emails claiming that taxpayers are ‘due an audit’ and directing them to click a link to schedule the audit by a specified date. Examples of fraudulent emails and text messages are included in the communication. Taxpayers who have provided Revenue account details in response to an email, SMS or phone call are advised to reset their password immediately. Taxpayers are advised to contact their bank or credit card provider if they have provided bank or card details.

Revenue has updated its guide on how to protect your business from becoming involved in VAT fraud providing examples of relevant due‑diligence actions which can be undertaken when establishing a trading relationship with a supplier or customer.

The Tax and Duty manuals on  Revenue Information Powers and the Schedule of Revenue Powers have recently been updated to provide additional clarifications and to outline Revenue’s approach in exercising the relevant legislative powers. The guidance on Information Powers outlines that Revenue will notify a taxpayer in writing where a notice has been issued to a third party under section 902 TCA 1997 or to a financial institution under section 906A TCA 1997. The guidance on the schedule of Revenue powers now includes a reference to section 109A VAT Consolidation Act 2010 which empowers Revenue to require a taxable person who is not established in the EU to appoint an EU‑established tax representative. That representative will be responsible for the payment of any VAT arising from the supplies made by the taxable person within the State.

Revenue has updated its guidance on the operation and administration of the Pillar Two rules. The revised material provides additional detail and clarification on the application of the rules, offering further insight into how they are to be interpreted and implemented in practice. The relevant sections of the guidance on the operation of Pillar Two which have been updated are as follows: Section 5.1, to update guidance in respect of ultimate parent entities. Section 6.10, to update guidance in respect of section 111N - Calculation and allocation of UTPR top-up tax amount, as it relates to the allocation of UTPR among domestic constituent entities. Section 7.2, to update guidance in respect of intra-group financing arrangements and use of losses carried forward. Section 8.5 (section 111X – Total deferred tax adjustment amount) and section 12.1 (section 111AW – Tax treatment of deferred tax assets, deferred tax liabilities and transferred assets upon transition), as it relates to the utilisation of loss deferred tax assets, Section 9.6, to update guidance in respect of section 111AH - Minority owned constituent entities, as it relates to an orphan entity that is a constituent entity, Section 9.7 (section 111AI - Qualified domestic top-up tax safe harbour), Section 9.8 (section 111AJ - Transitional CbCR safe harbour) and section 12.1 (section 111AW – Tax treatment of deferred tax assets, deferred tax liabilities and transferred assets upon transition), as it relates to the treatment of certain deferred tax assets (DTA’s) arising from tax benefits provided by General Government, Section 13.3, to update guidance in respect of section 111AAC - Chargeable entities, as it relates to the reallocation of any QDTT calculated for a securitisation entity that is a minority owned constituent entity, and Section 13.4, to update guidance in respect of Section 111AAD - Determining top-up tax amounts of qualifying entity, as it relates to the application of the local accounting standard in calculating domestic top-up tax, in certain circumstances, notwithstanding that the fiscal year end does not align with that of the ultimate parent entity. The changes to the guidance on the administration of Pillar Two rules include: Updates with respect to the requirements of the Directive on Administrative Cooperation and the OECD Pillar Two Multilateral Competent Authority Agreement (MCAA), An update to reflect that the secondary collection mechanism for UTPR and QDTT liabilities do not apply to a securitisation entity in certain circumstances, and Updates with respect to the taxpayer obligation to keep records, the provision of related penalties for non-compliance, and Revenue’s power to inspect records. Several other minor amendments have been reflected throughout both documents.

Revenue has published updated guidance on the participation exemption for certain foreign distributions to reflect amendments contained in Finance Act 2025. Information on distributions‑in‑specie and how the tax deductibility of a distribution impacts the exemption claim are also included in the guidance. In general, for the purposes of the exemption, a relevant distribution does not include a distribution, or part of a distribution, that has been, or may be, deducted for tax purposes in any territory outside the State under the law of that territory. The guidance confirms that, from 1 January 2026, a distribution will not be excluded from being a relevant distribution solely because it is deductible for the purposes of a tax comparable to the close company surcharge in section 440 TCA 1997. Section three of the guidance, which outlines the conditions the foreign dividend-paying company must meet to qualify as a relevant subsidiary, has been updated to include the following information: Relevant distributions made on or after 1 January 2026 by a company resident in a non-EEA or non-tax treaty territory are in scope of the exemption if foreign withholding tax at a nominal rate greater than zero per cent is paid on the full amount of the distribution and not refunded. The definitions of “relevant period” and “reference period” are reduced from five years to three years, reducing the period in which a company must be resident in a relevant territory, or have not had certain excluded merger and acquisition activity, prior to making a distribution. In cases where the domestic law of a relevant territory does not determine a company’s residence, the residence position will be determined under the terms of the relevant territory’s tax treaty with Ireland. A company resident in a territory with which Ireland has a newly signed tax treaty is eligible to qualify as a relevant subsidiary from the date of signature of that tax treaty. In the case of a relevant distribution made on or after 1 January 2025, a distributing company is permitted, during the reference period, to have acquired a business or business assets consisting of shares, or to have moved residence from Ireland, or to have had merger and acquisition activity involving an Irish resident company.

Revenue has updated its guidance on termination payments with an additional example in paragraph 3.3.1. The example relates to unpaid protective leave and confirms that such leave does not constitute a gap or break in service when calculating complete years of service for the purposes of any potential relief available. The guidance also explains that protective leave includes carer’s leave, maternity leave, and parental leave.  

Revenue issued a press release last week confirming that Local Property Tax (LPT) returns and payments have been now made for over 1.9 million properties, as part of last year’s revaluation process. However, the statistics show that returns in respect of approximately 390,000 properties remain outstanding, albeit payment arrangements are in place in respect of 227,000 of these properties. Revenue is requesting all residential property owners who have not filed an LPT return to do so immediately. Revenue has advised that it will be writing to non-compliant property owners as part of its LPT compliance campaign. For property owners who have not yet made arrangements to pay their 2026 liability, a range of flexible payment options remain available including payment by direct debit or salary deduction over a reduced ten-month period, or alternatively a single annual deduction. Compliance letters will shortly issue to property owners in employment where a return has not been filed or where a payment arrangement is not in place. Property owners in this category will be given a two‑week deadline to submit their return and payment. If they fail to do so, Revenue will instruct their employer to begin deducting LPT from their employment income. Further correspondence will issue in due course to other categories of property owners. For the 227,000 property owners who have payment arrangements in place but have yet to file a return, Revenue is requesting these property owners to file their LPT return and update their valuation band as failure to do so will result in enforcement action. Revenue’s website includes an interactive valuation tool to assist property owners in assessing the value of their property which is intended as a guide only. We have outlined further relevant details in our earlier newsletter item. Updated property statistics are available on the Revenue website and includes the latest data for LPT, Vacant Homes Tax and Residential Zoned Land Tax.

In last week’s Tax Newsletter, we notified readers that we received an invitation to present before the Joint Committee on Finance, Public Expenditure, Public Service Reform and Digitalisation as part of the pre-legislative scrutiny of the Finance (Tax Appeals and Fiscal Responsibility) Bill 2025. You can now watch that session in full here. The invitation was received following our submission to the Committee in December. In our opening statement and in response to the questions raised by the Committee, we highlighted two fundamental concerns with the proposals in Head 5 of the Revised General Scheme of Finance (Tax Appeals and Fiscal Responsibility) Bill 2025, being the protection of taxpayer privacy and the shifting of power too far toward the State. We expressed our unequivocal support for the protection of taxpayer privacy, and our position is that the right to elect for a private hearing should be preserved at the Tax Appeals Commission as a court of first instance. Tax appeals often involve deeply sensitive personal and financial information. For over a decade, taxpayers have had the right to request a private hearing at the TAC, with anonymised determinations still published to ensure transparency and accountability to the public. The legal principles underscoring a determination of the TAC are available to the public as it stands. Further, the nature of a Tax Appeal is that all information is provided at the outset of an appeal. A key reason for administering justice in public is to enable the public to provide information to ensure justice can be achieved. However, in the case of tax appeals, this requirement has already been satisfied by the legal obligations of taxpayers under the Tax Acts. There obligations demand complete transparency of all financial information to Revenue for the purposes of filing an accurate and complete tax return. We also expressed our grave concerns that shifting balance of power toward the State risks undermining the spirit of voluntary compliance that underscores the entire self-assessment model. Removing the taxpayer’s right to elect for a private hearing risks deterring compliant taxpayers from seeking independent adjudication of Revenue’s legal interpretations thereby eroding trust and transparency and undermine confidence in the overall appeals process.  Paradoxically, those who deliberately default may still protect their privacy where they are seen to cooperate with Revenue, while compliant taxpayers will now likely lose that right in most cases. The proposed amendments draw on the Supreme Court’s decision in Zalewski v the Workplace Relations Commission. However, that case involved an absolute ban on public hearings; the Tax Appeal Commission is already public by default. The proposals go far beyond what the Constitution requires—and in doing so, places taxpayer rights in the hands of a quasi-judicial body, rather than preserving the longstanding statutory protections afforded to compliant taxpayers. At a time when voluntary compliance underpins our self‑assessment system, it is vital that taxpayers retain a meaningful, reliable right to privacy in tax matters. The proposed amendments would significantly undermine that principle.

Institute responds to consultation on upcoming Northern Ireland Budget 2026 Chartered Accountants Ireland has urged the Northern Ireland Executive to prioritise measures that will help attract investment, support entrepreneurs and enable more people to participate in the workforce. The Institute made the recommendations in its submission to the public consultation on the upcoming Northern Ireland Budget 2026. Grant Sweetnam, Head of Public Policy at Chartered Accountants Ireland said:  “Northern Ireland has enormous economic potential but realising that potential requires a consistent, coherent and long-term industrial policy that attracts investment, creates secure, well-paid jobs and fosters entrepreneurialism and innovation. “Entrepreneurs and foreign direct investment are central to growth, and they need a tax system that encourages ambition and innovation. At the same time, removing barriers to cross-border working and investing in affordable childcare would make it easier for people to participate fully in the labour market. “Taken together, these measures would strengthen competitiveness, attract investment and support sustainable economic growth for the long term. In an environment of geopolitical upheaval these are measures that are within the government’s control.” Improving cross-border working arrangements The Institute highlighted the growing importance of cross-border and hybrid working across the island of Ireland, noting that current tax and administrative rules can create challenges for both employers and employees when frontier workers spend part of their time working from home. To support a more integrated all-island labour market, the Institute is urging the Executive to work with HM Treasury and the Government of Ireland to reduce administrative burdens and address disparities in the tax treatment of pension contributions and retirement income. Exploring a reduced corporation tax rate Chartered Accountants Ireland also calls for renewed efforts to reduce the corporation tax rate in Northern Ireland, suggesting the Department of Finance and the Department for the Economy commission an economic analysis on the potential impact of this reduced corporation tax rate. Sweetnam said: “A competitive corporate tax rate could help attract investment, create well-paid jobs and encourage innovation and entrepreneurship and we urge the Executive place a renewed focus on achieving a lower corporate tax rate. “The Institute also called on the Executive to invest in, and reform Invest NI to strengthen its ability to build relationships with major international companies and better promote Northern Ireland as a destination for investment.” Investing in childcare The Institutes submission highlights the economic benefits of affordable and accessible childcare. Greater childcare provision would help increase workforce participation and improve productivity. Sweetnam concluded: “Research conducted by the Institute found that 51% of respondents in Northern Ireland had either reduced their working hours or requested flexible working arrangements because of childcare pressures. “We welcome the publication of the draft Early Learning and Childcare Strategy and encourage the Executive and the Northern Ireland Assembly to prioritise childcare investment in the forthcoming budget.” Supporting entrepreneurs Chartered Accountants Ireland emphasises that entrepreneurs are central to economic growth, creating jobs and driving innovation across the economy. It calls for greater support through the tax system and warned of potential divergence between Northern Ireland and Great Britain as changes to the UK’s Tax Advantaged Venture Capital Schemes come into effect. The Institute argues that entrepreneurial tax supports should not be limited to high-growth companies alone, but should also benefit other businesses with strong growth ambitions. The Institute also suggests that a wider review of how the UK tax system can encourage entrepreneurship and business growth would be beneficial.

This week Chartered Accountants Ireland represented members in attending the Cost of Business Advisory Forum run by the Department of Enterprise, Tourism and Employment. The meeting follows the Institute’s submission recently where the focus was on banking, payments and financial services.  We outlined how banking services in Ireland, particularly on the payments side, is behind what is available as standard in other countries.  Competition is essential in moving the dial in terms of banking services and reducing costs for SMEs. We urged both the Central Bank and the Government to recognise that the lack of competition in the banking sector is a drag on the economy and needs to be acted on.    The Institute highlighted the need for the banking sector to move quicker to Account to Account (A2A) payment services.   A2A is an instant payment mechanism which does not need an intermediary card. A2A payments benefit businesses by reducing transaction costs, speeding up settlement and improving reconciliation through real-time data and automation.   At the moment payers end up using credit or debit cards to pay SMEs online and it is the SME that incurs the significant costs of availing of those services. In addition, it is very challenging for SMEs to track who is paying money into their account. This adds to administration cost for SMEs.  In terms of access to finance for SMEs, the Institute highlighted the need for Ireland to deepen the capital markets and improve retail investment in Ireland. We urged the Government to introduce a Savings and Investment Account in Ireland which will encourage workers and households to invest in SMEs.  Following this meeting, the Institute will continue to contribute to the Cost of Business Advisory Forum with the aim of completing a comprehensive report on business costs with important and achievable recommendations for Government. 

The Chairman of Chartered Accountants Ulster Society has called for a reduction in Corporation Tax as part of a wider, credible industrial strategy to drive investment, job creation and long-term economic growth in Northern Ireland. Speaking at the Ulster Society’s Annual Dinner, attended by almost 500 business leaders, policymakers and professionals, Chairman Mark Lawther highlighted the findings of the Society’s latest member survey, which points to ongoing economic uncertainty and the need for decisive policy action. “The global outlook remains unpredictable, and that uncertainty is clearly reflected at a local level,” said Mark Lawther. “Confidence in Northern Ireland’s prospects has dipped slightly, with fewer than 6% of our members currently describing the outlook as ‘good’. That underlines the scale of the challenge—and the urgency of the response required.” Ulster’s Chartered Accountants also voice significant concern around public finances, with 94% of members citing public sector funding pressures as having a negative impact on the local economy. “Public sector reform is seen by our members as the single most important priority,” he said. “Alongside that, there is a clear message that we are not yet making the most of Northern Ireland’s unique post-EU trading position, despite the real potential that exists.” Mark Lawther emphasised that Northern Ireland has strong economic fundamentals, including dual market access to Great Britain and the EU, a competitive cost base, and growing political stability. “After a period when certainty felt like a rare commodity, it is encouraging that we can now talk about stability not as an aspiration, but as a foundation,” he said. “That gives us a real opportunity to build momentum and create an environment where Northern Ireland—and its people—can genuinely thrive.” However, he stressed that unlocking this potential will require bold and coordinated action. “A reduction in Corporation Tax, as part of the right policy mix, could be genuinely transformational,” he said. “It would allow us to leverage our unique market position, attract global investment, support local businesses, and create high-value jobs.” “In recent months, we have engaged with all five of Northern Ireland’s main political parties on this issue. As people who live and work here, and who care deeply about its future, we believe that a competitive Corporation Tax rate could be a game changer for our economy.” Reflecting on the role of the profession, Mark Lawther highlighted the contribution Chartered Accountants make across the economy. “Chartered Accountants are at the heart of business and public service, supporting organisations to adapt, grow and innovate,” he said. “We don’t just witness change—we help make it happen. Every day, our members are working alongside businesses that are evolving and expanding, helping to build a more competitive and resilient Northern Ireland.” He also welcomed the attendance of the First Minister and deputy First Minister, noting the importance of political leadership and engagement with the business community. “Business thrives best in an environment of certainty, collaboration and ambition,” he said. “We very much value the leadership shown in restoring stable government and in setting a constructive tone for the work of the Executive.” The Annual Dinner, sponsored by Danske Bank and MCS Group, celebrated the contribution of Chartered Accountants across Northern Ireland and brought together leaders from across industry, professional services and enterprise.  

This week the Institute met with Minister of State for European Affairs and Defence, Thomas Byrne TD, and officials as preparations continue to gather pace for Ireland’s Presidency of the Council of the EU (‘EU Presidency’), now just three months away.  The meeting provided an opportunity to talk through Chartered Accountants Ireland’s submission on the Presidency and to set out what we believe Ireland’s priorities should be over the six‑month term with a focus on competitiveness and simplification.  Against that backdrop, the discussion focused on the importance of progressing two key initiatives: EU Inc. and the Savings and Investment Union. We emphasised that securing meaningful progress on these proposals within the six‑month window would represent a highly successful Presidency and would be of significant strategic importance for Ireland and the wider EU economy.  Chartered Accountants Ireland reaffirmed its commitment to working constructively with Government in the lead‑up to, and throughout, the Presidency. With a 40,000-strong membership across Ireland and internationally, the Institute is well placed to support engagement, understanding and debate on key Presidency priorities.  Looking ahead, members can expect a programme of activity by the Institute during the six‑month Presidency, including publications, briefings and events focused on competitiveness and simplification. These initiatives will be designed to keep members informed, to showcase professional insights and to contribute positively to Ireland’s Presidency objectives. Further details will be shared in the coming months, and members are encouraged to keep an eye on Chartered News and Institute channels for updates.