Last Wednesday, representatives from the Institute met with members of the Northern Ireland Assembly’s Finance and Economy Committees in Stormont to discuss the Institute’s ongoing campaign to reduce the corporation tax rate in Northern Ireland. The Institute spoke about the need for a coherent long term industrial policy in Northern Ireland that attracts investment, creates secure, well-paid jobs, and fosters innovation and entrepreneurship. As part of this overall industrial strategy, Northern Ireland needs to reduce its corporation tax rate and provide policy certainty for potential investors. The feedback from members of each committee was positive and informed. It was clear that they are deeply committed to improving the economic environment in Northern Ireland and the living standards of all citizens. The key issues and Institute stance Addressing the challenge of the impact on the block grant that Northern Ireland receives every year, the Institute outlined various measures that could be utilised to mitigate the block grant reduction, most notably the use of a low interest loan from Westminster to manage the initial drop in corporate tax revenue that would arise immediately after a corporation tax rate reduction. Phased introduction of a lower corporation tax rate could also be implemented to reduce the immediate impact on the block grant. From an economic perspective, previous research from the ESRI shows that a reduction in corporate tax rates would increase investment in Northern Ireland by 7.5 percent which would also lead to substantial employment opportunities for people in the region. Progress to date and next steps  The next step is to take the campaign to Westminster to push the agenda forward. As part of this, the need for cross party support to reduce Northern Ireland’s corporation tax rate is crucial in order for progress to be made with HM Treasury; this point was also highlighted during last Wednesday’s meeting.  To begin progressing the issue nationally, last November the Institute wrote to the Exchequer Secretary to the Treasury on this issue which highlighted that the ultimate aim of a lower rate is for it to become self-funding in the longer term, but that initially it would necessitate a replacement loan at a low interest rate from HM Treasury to fund the necessary block grant reduction. To date, the Institute has met with a broad range of stakeholders on this issue and has now met with all the major political parties represented in the Northern Ireland assembly.  Last year the Institute launched its refreshed campaign for a lower corporation tax rate when it published its position paper ‘Enhancing Our Competitiveness: The case for a reduced rate of corporation tax in Northern Ireland’. Share your experiences and insights If you work in a local business and would like to participate in the Institute’s campaign by being a voice of support for a lower rate, contact us by email.

There are a number of non-routine deadlines arising this week for taxpayers and agents. On the tax payment front, there is the disclosure opportunity for businesses to regularise payroll obligations for 2024 and 2025 following the Karshan case (explained further below). The deadline for disclosures is 5pm on Friday 30 January 2026. On the consultation front, two ongoing public consultations, on electronic withholding tax (eWHT) and VAT modernisation also close at 5pm on Friday 30 January 2026 . We have included further information below as well as in our newsletter last week. We strongly recommend that readers complete these surveys if applicable. Please note that you do not need to include the identifying information at the start of the surveys to progress and Revenue has advised us that surveys without taxpayer identification numbers and other such information will still be accepted by them. The disclosure and settlement opportunity to regularise payroll obligations for 2024 and 2025 gives businesses, that may have misclassified employees as contractors, the mechanism to have the correction treated under the Code of Practice for Revenue Compliance Interventions without the imposition of interest and penalties.  Further details of the disclosure opportunity are available in our newsletter item last week. The joint public consultation on eWHT is inviting stakeholder to share feedback on a proposed electronic withholding tax (eWHT) system in Ireland, which aims to introduce real-time taxation for self-employed taxpayers subject to withholding tax (WHT). Further details are available in our earlier newsletter feature. The VAT modernisation survey is aimed at VAT-registered businesses managed by Large Corporates Division and will inform Ireland’s implementation of the EU’s VAT in the Digital Age (ViDA) package and the implementation of eInvoicing in Ireland. Further details are available in our earlier newsletter items.

There’s just five days to the 2024/25 online self-assessment (SA) filing deadline on Saturday 31 January 2026. By way of reminder, on Saturday 31 January HMRC will be operating a restricted service with assistance only available via webchat and no telephone support available on 31 January, except for a call-back service for vulnerable taxpayers. Anyone who may need to call HMRC for assistance before filing a return is therefore advised to file that return on or before Friday 30 January 2026 to ensure they are able to call HMRC and receive the necessary assistance. HMRC has also asked us to remind agents who are using the SA reactivation option on the Agent Dedicated Line (ADL) that telephone agents on this part of the ADL cannot deal with other general SA queries. Option 1 on the ADL (the reactivation option) is for SA reactivations only. Advisers are unable to address any other SA enquiries via this route and are also unable to transfer the agent to the general enquires line.  Selecting the wrong option increases the time that the agent can get their issue resolved which causes frustration for the agent and adviser alike.

Revenue has published new guidance on the enhanced deduction for eligible construction expenditure introduced by Finance Act 2025. The enhanced deduction allows companies to claim 25 percent of eligible construction costs, up to €50,000 per apartment, for completed developments. In broad terms, a completed development refers to a qualifying apartment block that meets certain defined conditions. A qualifying apartment block is a multi-storey building comprising of at least 10 apartments and is either:  a newly constructed building, or  a building or structure that, as part of a qualifying refurbishment, has undergone a material change. To claim the enhanced deduction, the company must be a relevant person which is specified as a property developer or a relevant contractor. The relevant person must be carrying out a relevant property development trade or a qualifying trade when developing the completed qualifying apartment block and the deduction must be pro‑rated based on the company’s beneficial ownership share in the development. The enhanced deduction is in addition to the standard trading deduction and further details of the definitions are included in the guidance together with examples and calculation information.

In this week’s detailed miscellaneous updates which you can read more about below, the Scottish and Welsh Budgets have been published and HMRC has published draft regulations for technical consultation on the construction industry scheme (CIS). In other news this week: As the latest Finance Bill makes its way through Parliament, HMRC has published a collection page of supporting documents related to the Bill and its passage,  Agent Update 139 is available, 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. Scottish and Welsh Budgets The Scottish and Welsh Budgets took place earlier this month. The Scottish Parliament has published a tax infographic for the Scottish Budget 2026/27 and the Scottish Fiscal Commission’s Report, Scotland’s Economic and Fiscal Forecasts – January 2026 is available along with a one-page graphic of key figures and a summary document. More detailed information on the Welsh Budget is set out in the detailed spending plans. Changes to the CIS HMRC has published draft regulations for technical consultation that are intended to simplify administration of the CIS. The proposed changes include: an exemption for payments made to local authorities or public bodies from the scope of the CIS. and a requirement for construction contractors to file a nil return when they have not paid any subcontractors in a month, unless they have notified HMRC in advance that they will not make any such payments that month. The proposed changes will take effect from 6 April 2026. The technical consultation closes on 3 February 2026.

In this week’s cross-border trading corner, we bring you the latest guidance updates and publications. 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. HMRC has also sent a reminder that from 15 December 2025, traders can no longer use the same process in the Customs Declaration Service (CDS) for handling indirect exports end-to-end from Northern Ireland. Change to the CDS process for indirect exports From 15 December 2025, traders can no longer use the process in the CDS for handling indirect exports end-to-end from Northern Ireland. Indirect exports are movements that start in Northern Ireland and depart from a port of exit in a European Union (EU) member state, rather than being directly moved from a port or airport in Northern Ireland. However, traders can still use the CDS for goods exiting via Ireland. There are alternative ways to move goods depending on the circumstances which HMRC has set out below: “Alternative ways to move goods   You can continue to move your goods using the alternative processes below. You should check that the process you choose is appropriate for your circumstances; these are: Submit your export declaration in CDS if you’re moving goods through a port of exit in Ireland - if you use this process, you must ensure that: the Export Declaration must include the Additional Information (AI) code: ‘AG999’ in DE 2/2, the Office of Exit code the goods are intended to exit from in Ireland is entered in DE 2/2 against code AG999,  D/E 5/12 Office of Exit must show the Office of Exit as matching the Office of Export, your haulier carries a copy of the export declaration, either in paper or electronic format, you include the Movement Reference Number (MRN) of the declaration in the Irish Revenue’s Pre-Boarding Notification (PBN) for movements exiting on a roll on roll off, or you provide the MRN to the airline or handling agent for movement exiting via air. If you do not follow this guidance and enter the Office of Exit as an EU location in DE 5/12, it is no longer possible to close your declaration. Please note this option does not apply to exits via other EU member states. Declare a direct export with the Customs Authority where the goods depart – this option is only available if the goods are under €3,000 in value and are not subject to licence controls,  Use the Common Transit Procedure where the destination is within a Common Transit Convention (CTC) country – this can include Great Britain which is a signatory to the CTC. Read further guidance on the CTC.  Make changes to the routing and move the goods directly from Northern Ireland, as the majority of qualifying Northern Ireland goods  do not require an export declaration when moved directly from Northern Ireland to Great Britain, unless this is required to fulfil an international obligation – for example, for the movement of endangered species.  Move goods under a single transport contract  with an airline or shipping company who take over the carriage of the goods in Northern Ireland. Please note, this cannot be used for movements exiting by road, or goods subject to excise duty.  Arrangements for moving goods directly from Northern Ireland to Great Britain, either under unfettered access or in the limited circumstances where declarations apply, are unchanged.”  HMRC can be contacted for any queries on this change via email to AESteam@hmrc.gov.uk.  Miscellaneous guidance updates and publications This week’s miscellaneous guidance updates and publications are as follows: Designated export place (DEP) codes for Data Element 5/23 of the Customs Declaration Service External temporary storage facilities codes for Data Element 5/23 of the Customs Declaration Service Bringing commercial goods into Great Britain in your baggage CDS Declaration Completion Instructions for Imports Transit newsletters — HMRC updates Reference Documents for The Customs Tariff (Suspension of Import Duty Rates) (EU Exit) Regulations 2020 Reference Document for The Customs Tariff (Establishment) (EU Exit) Regulations 2020

Revenue has published updated guidance relating to offshore funds and investment undertakings to reflect the reduced 38 percent tax rate for individuals introduced by Finance Act 2025 and effective from 1 January 2026. The rate reduced from 41 percent to 38 percent and applies in respect of income and gains from Irish domiciled investment funds and equivalent offshore investment funds in other EU Member States, EEA States and OECD countries with which Ireland has a double taxation agreement.

Revenue has updated its guidance on the anti-avoidance provision relating to interest on loans to defray money applied to certain purposes to reflect changes introduced by Finance Act 2025. The section on the ‘sole business of trading’ has been revised to reflect recent changes, and a new paragraph (5.3) has been added to outline the connected loans exceptions and includes relevant examples.

Revenue has updated the guidance on the exemption available in respect of compensation for certain living donors to reflect changes introduced by Finance Act 2025 arising from the enactment of the Human Tissue (Transplantation, Post-Mortem, Anatomical Examination and Public Display) Act 2024. The updated guidance outlines the legislative changes made in Finance Act 2025 and provides updated background details to the exemption provided under Section 204B TCA 1997. A new section has been included in the guidance to outline details of payments qualifying for exemption.

The OECD has published a fourth batch of updated transfer pricing country profiles. The information is intended to reflect the current state of countries' legislation and the extent their rules follow the OECD Transfer Pricing Guidelines.

Revenue has revised two of its close company guidance notes by reorganising the material and including additional information and examples illustrating how the provisions operate. The relevant manuals relate to certain settlements made by close companies and treatment of interest payments and other forms of consideration as distributions. The guidance on certain settlements made by close companies  relates to the provisions of section 436A TCA 1997 and the transfer of funds from close companies through the use of trusts and other arrangements. The guidance on the tax treatment of certain payments made by close companies to participators and directors under sections 436 and 437 TCA 1997 outlines how these provisions classify interest payments that exceed specified limits, as well as expenses incurred in providing certain benefits, as distributions.

The FISC Subcommittee will host a public hearing on  tackling tax obstacles in the Single Market on Tuesday, 27 January 2026. At the hearing, experts will outline their views and discuss with members on ways to tackle the remaining tax-related obstacles and barriers in the Single Market.