Following constructive engagement with Government departments, the Institute has secured a change which should make the process of hiring non-EEA accountants by way of a Critical Skills Employment Permit (CSEP) less burdensome. In recent months, member firms have reported to us a significant increase in the need to apply for bridging CSEP visas for their workers while their residency status is being processed.  New rules announced this week should substantially reduce this requirement. CSEP’s are valid for a period of two years, after which employees holding this permit can typically go on to apply for continued residence in Ireland under what is known as a Stamp 4. Since November 2023, in order to secure a Stamp 4, the holder of a CSEP was required to complete a minimum of 21-months' work following the issuance of a Stamp 1 (a permission to work visa). Delays in issuing a Stamp 1 meant that member firms have had to apply for bridging CSEPs because the 2-year CSEP would expire before accountants could meet the 21-month work requirement. Amplifying our members concerns, we called for a reinstatement of the previous system whereby a Stamp 4 could be secured 21 months from the commencement of employment in the State - rather than from the commencement of a Stamp 1. Following a sustained period of engagement with department officials, this suggestion was formally adopted by the Department of Justice with immediate effect – details of the changes can be found here. Chartered accountants are currently listed on the Government’s Critical Skills Occupations List – meaning that due to capacity shortages in the industry, suitable candidates from non-EEA jurisdictions are eligible to apply for a Critical Skills Employment Permit (CSEP) to come and work in the profession here. The Department of Enterprise, Trade and Employment and the Department of Justice have jurisdiction over the issuance of CSEP’s and Stamp 4 residence permits. Further information on CSEPs can be found here on gov.ie. The previous changes announced by the Department of Enterprise, Trade and Employment (DETE) on November 15 2023 can be found here. Should you have an issue which you would like to bring to the attention of the public policy team, please reach out via our email publicpolicy@charteredaccountants.ie

Embracing a positive perspective is a key ingredient for personal wellbeing. Aaron O’Connell asks you to consider whether you’re a glass half full or glass half empty person, and he provides a useful exercise to help you view life with a different filter and to boost your well-being. Some questions for you to consider Do you have tendency to see things positively where you are focusing on the good things that happen around you, or do you focus on the negatives, those obstacles and problems you face?  If you have a to-do list and you manage to successfully complete 19 out of 20 things, are you happy about the long list of things you’ve accomplished, or are you upset about that one thing that you didn’t get to finish? It’s your choice A hundred good things (little highlights) and one bad thing (a little low-light) might happen during your day. You have the opportunity to appreciate and remember all the good things, or to focus only on the bad things. You can look at life through a different filter. Embracing a positive perspective One useful exercise I recommend to the athletes, students and business people I work with, and indeed practice myself every night at bedtime, is to recall seven positive things that happen during the day. It’s something I picked up from internationally acclaimed sport psychologist, Dr. Terry Orlick. Before you sleep, look back over your day chronologically and highlight those good things that happened. They don’t have to be major events. Little highlights will do. “I had a lovely breakfast.” “The sun was shining today.” “I got a call from a good friend.” “I went for a lovely walk today.” You could begin this exercise by recalling three positives and increase by one each time after a few days. Look for different ones each day. As Dr. Orlick would say, it’s like “using a yellow magic marker to highlight all the good things you do, see, hear, taste, feel, and learn in a day.” Even better, write them down in a journal or on your phone. You’ll get a buzz out of revisiting and re-reading these when you’ve had a tough day. Using a different filter and living with a positive perspective is like becoming your own best friend. It’ll change your outlook in life for the good. Challenge yourself to look for seven highlights a day. Once you start looking for them and finding them, your day and your life immediately become better. You’ll experience a boost in wellbeing along with an increase in gratitude. Aaron O’Connell is the owner of Mind Your Performance. He provides consultancy and training in mental skills, mental well-being, and performance enhancement for the education, business, and sports sector. Thrive is the Institute’s dedicated wellbeing hub which provides emotional and practical support to our members, students, and their family members for life. Should you find yourself in a difficult situation, the team at Thrive can help steer you through life’s ups and downs.  Talk to us today on mobile: (353) 86 024 3294 or email us.  

From the Institute's  Professional Accounting team : Introduction On 15 March 2024, the Irish Department of Enterprise, Trade and Employment (DETE ) published the General Scheme of Companies (Corporate Governance, Enforcement and Regulatory Provisions) Bill 2024 (“General Scheme”) to make amendments to Companies Act 2014 (CA 2014).Please click here for the press release on the General Scheme. Click here for the text of the publication and the regulatory impact analysis of the General Scheme. Readers may recall that DETE conducted a public consultation on proposals to enhance the CA 2014 (“Consultation”) last year. The Institute responded to that consultation and you can click here to see the response. The General Scheme is wide ranging, and we set out below some of the proposed provisions which if enacted may be of interest to members. Please also refer to the Corporate Enforcement Authority’s press release and accompanying note dated 15 March 2024 which provides detailed information on proposed enhancements to the CEA’s powers and some proposed new offences. Electronic meetings There are proposals to put electronic participation in meetings on a permanent statutory footing and to include provisions for notices, quorum and proceedings and virtual voting at such meetings. Readers may recall that in December 2023 these provisions which were introduced during the pandemic were temporarily extended to 31 December 2024. Audit exemption A change to the rules regarding the loss of audit exemption for companies which fail to file their annual return on time is proposed. It is proposed that if a small company fails to file its annual return with the Companies Registration Office for a second or subsequent time within a period of 5 consecutive years, then the company will lose its ability to claim audit exemption. The current legal position is that the exemption is lost after one failure to file. This proposal is welcomed by the Institute which has lobbied for some time for the change. The Institute recognises the importance of companies complying with legal obligations as regards the publication of financial information. However, it considers that the loss of audit exemption for two years for a late filing to be an overly punitive sanction. Provisions relating to receivers Some changes relating to receivers are proposed. New provisions are proposed requiring the provision of further information on Form E8 which is filed upon the receiver’s appointment. The further information includes details of nature of assets, date and nature of appointment, information regarding future trading where practicable, and other prescribed information. Also, it is proposed that the time limits for filing the receiver’s abstract (Form E9) upon cessation of acting as receiver and notice of cessation of receiver (Form E11) will now be 7 days. Provisions concerning entitlement to remuneration of receivers are proposed in line with existing provisions in the CA 2014 concerning entitlement of liquidators to remuneration. Members, creditors, and prescribed persons can request information regarding receivers’ terms and fees, and requests must be dealt with within 7 days. It is proposed to extend the existing power of the court to fix remuneration of a receiver. Matters to be taken into account for receivers under these proposals include time spent, complexity of the case, exceptional responsibility on receiver, effectiveness of receiver, value, and nature of the property. This mirrors existing provisions for remuneration for liquidators in the CA 2014. DETE had suggested in the Consultation last year that there is merit in amending the CA 2014 to provide that receivers are subject to minimum qualifications along the lines of the qualification requirements for liquidators as set out in the CA 2014. However, there are no such proposals in the General Scheme. Provisions relating to SCARP The provisions relating to SCARP are largely technical amendments and corrections of the Companies (Rescue Process for Small and Micro Companies) Act 2021. Much of the amendment is also to make provision to give notifications “in prescribed form” to the Registrar of Companies and court.  An amendment to the section on the process adviser’s (PA) remuneration costs and expenses proposes that the court can ask the PA for a written report where the PA did not make use of the services of the staff and facilities of the company to which they were appointed where the court is considering any matter relating to the PA’s costs, expenses, and remuneration. Winding up Most of the amendments are to make provision to give notifications “in prescribed form” to the Registrar of Companies. The only proposal of note is an amendment to the section of the CA 2014 which imposes an obligation on a liquidator to apply to the Court for the restriction of a director or directors of an insolvent company. The liquidator may be relieved of this obligation by the CEA. The proposed amendment is to make explicit that the obligation on liquidators endures all the way through to the end, which includes to the end of all appeals proceedings against restriction orders. Strike off and restoration Three new grounds for involuntary strike off are proposed, failure to notify of a change in registered office, no current company secretary recorded and failure to deliver beneficial ownership information. There are some consequential amendments proposed on foot of the three new proposed strike off grounds. These three new proposed grounds will not give rise to disqualification of the directors and the new proposals include the steps to be taken to avert continuation of the strike off under the three new grounds. Provisions relating to the Corporate Enforcement Authority Changes include for example mechanisms for the CEA to receive details of restriction and disqualification orders and reliefs to restricted persons more quickly than at present. An amendment is proposed to section 393 of the CA 2014. This section requires an auditor to notify the CEA if during the course of an audit the auditor comes into possession of information leading them to form the opinion that there are reasonable grounds to believe a category 1 or 2 offence under the CA 2014 has been committed. The amendment requires the auditor to furnish the CEA with copy books and documents or extracts (the current provisions require grant of access to books and documents) and a signed assurance from the audit partner that they are exact copies. New offences of obstruction and intimidation are proposed. Please see the CEA press statement issued 15 March 2024 and accompanying note for a fuller summary of the proposals of the General Scheme which relate to the CEA. Provisions relating to IAASA It is proposed that IAASA will have power to issue an interim notice imposing restrictions on a statutory auditor that a possible relevant contravention has been committed and that it is appropriate in the public interest to do so .Relevant contraventions could be but are not limited to failure to obtain sufficient evidence to support an issued audited opinion, repeated significant deficiencies in standards of audit work or significant breach(es) of independence or ethics rules. IAASA will invite and consider submissions received from the restricted person and will within 21 days either confirm vary or revoke the interim notice. The restrictions remain in place until the investigation is complete. An interim notice will be reviewed every 6 months or a shorter period and automatically expires after 18 months unless a further interim notice is issued. IAASA will be required to make regulations regarding procedures to be followed under this proposal. Other Other miscellaneous proposals which might be of interest is a section whereby a company can provide voluntary information in its annual return on gender balance of its board of directors. The information would be collected for statistical purposes only. There are also proposals for multi located execution of documents and a proposed amendment so that weekends and public holidays are excluded from the time counted towards the minimum 48 hour notice required to appoint proxies. 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.  

Alan T. Ennis FCA is a board director, advisor and former CEO and president of Revlon Inc. His experience has taught him the power of pride in his achievements and advocating for himself. What do you value most about your membership of the profession? In everything I’ve done here in the US, my qualification as a Chartered Accountant has been the most valuable jewel in my chest of knowledge. Even today, my finance background continues to be invaluable in terms of buying and selling businesses, understanding capital structures and capital markets.  It has been the same throughout my career. I put a lot of my progression at Revlon down to my training. I could understand financial statements, I understood the importance of profitability and cash and how investments work. I could talk to the Board of Directors in those terms and it was invaluable. What advice would you have for other Chartered Accountants thinking of moving to the US? My advice is to make sure you start to connect with other Chartered Accountants over here straight away – and there are lots of us in New York, Boston, San Francisco and other places. That’s a valuable network. The other piece of advice I would have is that it’s okay to put yourself out there – in fact, it’s a good idea. Americans tend to be confident in how they present themselves professionally. They are proud of what they have done and they're confident in their success and in their abilities.  They're not afraid to talk about it. Irish people, myself included at times, tend to downplay our achievements and abilities. In the US, people won’t necessarily understand that so it’s not a bad idea to learn to advocate for yourself, your skills and talents. What made you choose to become a Chartered Accountant? I studied commerce at University College Dublin, graduating in 1991. Going through the BComm in those days, you had two options: you could follow the management track or the accounting track. The management track covered topics like organisational design, leadership, strategy and marketing. I said to my dad, “I think I'm going to choose that,” and he replied, “oh no, you should do accounting.” At that time, I didn’t think I wanted to be an accountant, but my dad said to me said, “you do, you just don’t know it yet.”So, I followed the accounting track, joined Arthur Andersen in 1991 and raced through my Chartered Accountancy exams. Can you tell us a little about how you got to where you are today – both your relocation and career path? When I was training with Arthur Andersen, I understood how beneficial training in accounting could be in business. I was fairly certain that I wouldn’t stay in the auditing field and become a partner in an accounting firm.  That wasn’t what I wanted to do. I wanted to become a Chartered Accountant and then move out into industry, but I did stay with Arthur Andersen for a while, becoming a manager before leaving Ireland in my mid-twenties.  I moved to the UK to join Ingersoll Rand in Manchester and then negotiated a transfer to the company’s New Jersey office in 1999. I moved through various financial roles from internal audit to financial planning and investor relations. In 2004, I was offered a new position as CFO of Ingersoll Rand’s Bobcat division in North Dakota. At the same time, I was offered the position of Head of Internal Audit at Revlon.  I was in my early thirties and my choice was between Bobcat in Fargo, North Dakota, and this other role with a very different and much smaller company that would put me right in the heart of New York. I chose Revlon. Can you talk us through your experience at Revlon? Being a Chartered Accountant put me in a very good place to understand the financial operations of any corporation and that really stood me in good stead at Revlon. It had a lot of debt at the time. Joining the company was a high-risk move, but I thought, “you know what, I’m going to go for it.”  Within two-and-half years, I had gone from Head of Internal Audit to Corporate Controller to President of International and then Chief Financial Officer. Eventually, I was appointed Chief Executive, a position I held for five years reporting to the company’s Chair, Ron Perelman. What about your work now? I had a great run at Revlon and a superb team of people behind me. When I left that role in 2014, I got a great package and I wasn’t really under pressure anymore to prove myself. I had choices. I’ve since dabbled in private equity and joined a couple of boards, both profit and not-for-profit. The board that occupies most of my time right now is Nutrabolt, a sports nutrition company whose leading product is C4, a pre-workout energy drink. I am the company’s Vice-chair, Chair of the Audit Committee and a member of the Nominating Governance Committee. I’m also Nutrabolt’s lead Independent Director.  Alan T. Ennis is on numerous boards across a variety of industries, including at present the IDA and Nutrabolt. 

IAASA has issued a revised version of ISA (Ireland) 505 – External Confirmations. The main changes to the standard relate to: Clarification on what constitutes an electronic external confirmation. Prohibition on the use of negative external confirmations. Strengthened link with ISA (Ireland) 330 The Auditor’s Responses to Assessed Risks. Enhanced requirements concerning the investigation of exceptions. The revised standard is effective for audits of financial statements for periods beginning on or after 15 December 2024, with early adoption permitted. The revised ISA (Ireland) 505 is available here.

Last Tuesday 19 March 2024, HMRC announced a range of permanent changes to helpline services. However, the next day HMRC announced that the changes were being halted while HMRC “considers how best to help taxpayers harness online services”. Whilst the decision to further consider this issue is welcome, it is disappointing that feedback provided by the Institute and other Professional Bodies which raised various concerns about the proposed changes appears to not have been fully considered before the formal announcement was made last week and subsequently reversed. The Institute will engage with HMRC as it considers the way forward. Members are encouraged to provide feedback on HMRC services on a regular basis.

In Irish news, we bring you an update from the recent meeting of the main Tax Administration Liaison Committee (TALC) and Revenue has provided an important update regarding R&D claims for 2022 and 2023. In UK news, HMRC has halted the changes and restrictions to various helplines that were announced earlier this week, and today is your last opportunity to provide information to us on VAT margin scheme vehicles brought into Northern Ireland from Great Britain before 1 May 2023 which remain unsold. In International news, the European Commission has commenced a public consultation seeking feedback on the Directive on Tax Dispute Resolution.  Ireland Read our update from the recent meeting of the main Tax Administration Liaison Committee (TALC). Revenue has provided an important update regarding R&D claims for 2022 and 2023. UK The changes and restrictions announced by HMRC earlier this week in respect of various helplines will now not go ahead. Today is your last opportunity to provide information to us on VAT margin scheme vehicles brought into Northern Ireland from Great Britain before 1 May 2023 which remain unsold. International The European Commission has commenced a public consultation seeking feedback on the Directive on Tax Dispute Resolution. Keep up to date with all the latest Irish, UK, and international tax developments through Chartered Accountants Ireland’s Tax Newsletter. Subscribe to the Tax News by updating your preferences in MyAccount. You can also read this week’s EU exit corner here.

Chartered Accountants Ulster Society says reduced Corporation Tax rate plus renewed FDI interest could kick start local economy The Chairman of Chartered Accountants Ulster Society has said that Northern Ireland’s unique post-Brexit trading position could be Northern Ireland’s key economic advantage in the year ahead. Speaking to 400 guests at the Ulster Society’s Annual Dinner, sponsored by Danske Bank and MCS Group tonight (20 March), Paul Millar said that chartered accountants across Northern Ireland had identified the key opportunities for the economy, with dual market access to the UK and EU rating highly. Another key opportunity identified by Ulster Society members was the potential to attract investment and boost job creation through a reduced Corporation Tax rate. Paul Millar said: “Two-thirds of our members believe that Northern Ireland can benefit from devolved Corporation Tax powers and a lower rate to match that of the Republic of Ireland.  “If we can combine dual UK/EU market access, a competitive Corporation Tax rate, plus take advantage of the renewed interest in investment into Northern Ireland from the USA and elsewhere, it could be a game changer. The talent is here, the success stories are here, and the potential is right here. “With the right approach, an entrepreneurial mindset and everyone pulling in the right direction we have a tremendous opportunity to be a unique business hub. If we can take that opportunity, it means a better standard of living for everyone with better job, public services and better prospects. “We live in straitened times, but we need to find solutions. We need to focus on opportunities because they are there. Strategic initiatives could have a big part to play.” Mr Millar’s speech also highlighted the role of political leadership and the need to build on the confidence generated by the restoration of the Northern Ireland Assembly: “It’s really positive that we now have restored political leadership back at Stormont, ready to face the challenge. We also have a great opportunity to create a resurgence in economic optimism and determination, spurred on by renewed leadership and a clear vision for the future. “Encouraging entrepreneurship is not just about financial gains. It's about empowering individuals, revitalising communities, and shaping a brighter future for generations to come. “Northern Ireland is a great place to live and a great place to do business. There is so much potential and much to be positive about. We need to work together, with the right mindset, to take the opportunity that is in front of us.” Providing entertainment for guests at the Ulster Society Annual Dinner were adventurer, entrepreneur and author Debra Searle MVO MBE, and one of Northern Ireland’s most highly regarded performers Peter Corry MBE. The Chartered Accountants Ulster Society’s Annual Dinner took place at Titanic Belfast and was attended by 400 members and their business guests.  

Background The Department of Children, Equality, Disability, Integration and Youth (the Department) has recently issued a document1 “Guidance Note for Core Funding Reporting Requirements Transitional Arrangements Year 1 and 2” (“the Department Guidance Note”) to entities providing childcare and early education services regarding the transitional arrangements for the application for funding under a new funding model called ‘Together for Better’.  These transitional arrangements will be in place for the next two reporting periods (years ended 31 August 2023 and 31 August 2024). Reporting regime This reporting regime includes a requirement that the childcare service providers (“client”) engage a professional accountant to submit a document called an ‘Income and Expenditure Template. CCAB-I have made the Department aware of the potential cost implications for an accountant providing this service to their client.  The following matters should be noted: The report is to cover expenses incurred on a cash basis for the year ended 31 August. The requirement is for expenditure incurred in the relevant period only, no accruals or prepayments. Income will be pre-populated in the online platform. Where your client has a different year end, time apportionment is not permitted. Important considerations for CCAB-I members CCAB-I has engaged with the Department over a number of months to discuss the nature and extent of work expected and the respective responsibilities of the client and the professional accountant and, in particular, the concerns regarding the request for the professional accountant to submit the report (as set out in the Department Guidance Note) on behalf of a client. There was positive engagement and much, but not all, of the feedback by CCAB-I on the process was reflected and incorporated into the final guidance. However, given the type of engagement, CCAB-I are making members aware of the potential issues and extant guidance which our members may consult. The Department Guidance Note sets out the responsibility for the data included in the report. See section 2 of the Guidance Note: “The Service Provider is responsible for fully complying with all financial transparency requirements in accordance with their Core Funding contractual obligations. The accountant relies on information provided by the Service Provider, who is responsible for disclosing all relevant information.” The Service Provider/client will make an online declaration on the platform provided by the Department that they have authorised a professional accountant2 to make the submission for them.  CCAB-I members are reminded of the relevant Code of Ethics issued by their professional body.  Independence The Department Guidance Note3 defines an accountant as someone who: "(a) has been admitted as, and is, a member of a prescriber accountancy body, (b) is currently practicing in the profession of accountant, (c) is not and never has been a principal officer or employee, or an owner or part owner, of the licensee in respect of whom he or she is preparing an accountant’s report, and (d) is maintaining such minimum level of professional indemnity insurance as is required by the prescribed accountancy body concerned." .Members should be cognisant of any conflicts with other engagements they may undertake for their clients.  When you are the Auditor  Where the accountant is the statutory auditor the Ethical Standard for Auditors (Ireland)4 applies and Section 5.129 prohibits the audit firm providing accounting services where the services would involve the firm undertaking part of the role of management or initiating transactions.  "S 1.24           In the case of a statutory audit, non-audit services shall not be provided that involve playing any part in management decision-taking of an entity relevant to an engagement. The firm shall not accept any engagement which includes the provision of services where it is probable that an objective, reasonable and informed third party would conclude that the firm or a covered person was playing a part in management decision-taking.  5.128          The provision of accounting services by the firm to an entity relevant to an engagement creates threats to the integrity, objectivity and independence of the firm and covered persons, principally self-review and management threats, the significance of which depends on the nature and extent of the accounting services in question and the level of public interest in the entity. 5.129            The firm shall not provide accounting services to an entity relevant to an engagement where: (a) the entity is a listed entity, relevant to an engagement by the firm, or a significant affiliate of such an entity; or (b) for any other entity: those accounting services would involve the firm undertaking part of the role of management, or initiating transactions; or the services are anything other than of a routine or mechanical nature, requiring little or no professional judgment.” When you are not the Auditor We recommend that members read the Department Guidance Note1 and that an appropriate letter of engagement and representation letter are in place where they undertake these engagements.  Members should refer to guidance documents issued by Chartered Accountants Ireland.  TA 06/2023 Grant Claims5 and the International Standard on Related Service ISRS 4400 (Revised) Agreed-Upon Procedures Engagements6 which give guidance on engagement acceptance and continuance and some general advice on agreeing the terms of engagement.  1 https://earlyyearshive.ncs.gov.ie/downloads/download-corefunding/   2 A professional accountant is defined as a member of a Prescribed Accountancy Body that comes within the supervisory remit of IAASA, •              Chartered Accountants Ireland. (CAI) •              Association of Chartered Certified Accountants (ACCA) •              CPA Ireland (CPA) •              Chartered Institute of Management Accountants (CIMA)  3 See Section of Guidance Note for Core Funding Reporting Requirements Transitional Arrangements Year 1 and 2. 4 https://iaasa.ie/wp-content/uploads/docs/media/IAASA/Documents/audit-standards/Ethical-Standard-Consultation/Ethical_Standard_Nov_2020_updated_June_3.pdf 5 https://www.charteredaccountants.ie/chariot/account/ta/TA06_2023.html 6 https://www.iaasb.org/publications/international-standard-related-services-isrs-4400-revised  

Chartered Accountants Ireland is delighted to have been shortlisted today for a Business & Finance ESG Award in the Company Award (SME) category. Now in their third year, these Awards shortlist across 18 categories to reflect the evolving ESG landscape. The Awards showcase the successes of ESG initiatives and examples of best practice, and the Institute was proud to share details in our submission of the measures we have taken so far to embed sustainability in the Institute, both in Dublin and Belfast. Well done to Susan Rossney, Stuart Maguire, Barry Dempsey and Brian Keegan for their leadership and work to date, and to our members and partners who have collaborated with us so far on this sustainability journey.

Revenue has updated the Tax and Duty Manual which provides guidance on the enhanced reporting requirements (ERR) for employers. The manual now provides guidance on an optional administrative practice regarding advance payments of travel and subsistence.  An advance payment of travel and subsistence to an employee or director is a perquisite and income tax, USC and PRSI must be deducted. These types of payments would therefore not typically fall within the scope of ERR as the payment does not relate to travel or subsistence incurred by the director or employee. However, when a claim for the related travel and subsistence is made to the employer, and the employer wishes to avail of the Section 114 administrative practice (i.e. not tax the travel and subsistence expense), a payroll adjustment must occur to give the effect of no tax applying to the expense amount incurred and at that point the payment becomes a reportable benefit for ERR. Revenue recognises that this may give rise to certain practical issues for employers in terms of its interaction and obligations with ERR requirements.  Therefore, Revenue will implement an optional administrative practice in respect of advance travel and subsistence payments.   Under this administrative practice, an advance travel and subsistence payment may be treated, in certain circumstances, as not being subject to tax via the payroll when paid, but instead treated as a payment where no tax is deducted in respect of travel and subsistence and therefore subject to ERR reporting at the time of payment. Then, when the expense is incurred and the claim submitted by the employee/director, the employer will be required to update their ERR submission to Revenue to reflect the actual travel and subsistence expense amount in respect of that employee/director. 

In this month’s public policy update, our policy team outlines its ongoing lobbying efforts on the issue of childcare, its representations to Government on how a change in process is impacting Critical Skills Employment Permit holders and the Institute’s recent submission to the Department of Social Protection on pensions auto enrolment. Advocating for improved childcare in the Republic of Ireland and Northern Ireland Following the publication of our recent policy paper Supporting Working Parents – The case for better childcare policy in the Republic of Ireland and Northern Ireland, efforts have been ongoing to engage with policymakers across the island of Ireland on this important issue. Last week, our public policy team met with officials from the Department of Children, Equality, Disability, Integration and Youth to discuss our members feedback on the issue and in particular to emphasise the need to improve capacity across the sector. Meetings have also been held with opposition parties on the issue including Sinn Fein so as to ensure our members voice is heard across the political spectrum. Following the restoration of the Northern Ireland Assembly, meetings have also been held with legislators from all political parties as work toward developing a new childcare strategy for the region advances. As part of these discussions, our policy team have emphasised the cost pressures our Northern Ireland members are facing with respect to obtaining adequate childcare and in particular the need to abolish the £10,000 cap on tax-free childcare. Our policy team will continue to advocate on the issue of childcare throughout the year and welcome members feedback on the issue which can be sent to publicpolicy@charteredaccountants.ie. Changes with Critical Skills Employment Permit / Stamp 4 process causing issues for member firms Following recent changes announced by the Department of Enterprise, Trade and Employment (DETE) on November 15 2023, holders of Critical Skills Employment Permits (CSEP) must now apply directly to the Department of Justice or their local immigration office (if living outside Dublin) for a Stamp 4 permission to continue to reside and work in Ireland following the expiration of their CSEP. To obtain a Stamp 4 on or after the 30 November 2023, CSEP holders must complete a minimum of 21-months' work following the issuance of a Stamp 1. In effect, this means that the eligibility to meet the 21-month test does not start from the day the worker started to work physically in Ireland (which was the case under the previous system); instead, the clock starts from the date the Stamp 1 is issued (which could be several weeks later). These changes have had an enormous impact on CSEP holders and their employers, who in many cases bear the financial cost of the visa application process on behalf of their employees. Specifically, given that the 21-month period required to apply for a Stamp 4 is now only deemed to have commenced after the CSEP holder obtains a Stamp 1, many CSEP holders are finding that their 2-year CSEP expires before they have met the 21-month period needed to obtain a Stamp 4. This is the result of extensive processing times, with some employees reporting up to 18 weeks wait for Stamp 1 applications, particularly in regional areas. Such employees cannot possibly meet the 21-month period before their CSEP expires, as they are not able to obtain their Stamp 1 within the parameters of their CSEP. As a result,  many member firms have reported the need to apply for a ‘bridging’ CSEP to cover these employees until they can meet the necessary 21-month residency period, which in turn has created additional financial and administration costs.   Our policy team have written to officials in both the Department of Justice and DETE to highlight this issue and to request a meeting to discuss how the new system may be adjusted to reduce the financial and administrative burden it has placed on our members. Representations to Government on Pensions Auto Enrolment The Institute’s policy team have also recently written to the Department of Social Protection on the need to allow businesses adequate time to plan for the introduction of pensions auto-enrolment. While the Institute has long been clear in our support for the introduction of auto-enrolment as a mechanism for increasing private pension coverage in the State, payroll services providers tell us that a lead-in time of at least 18 months would be required to properly adapt to this significant change. In order for auto enrolment to be a success, we are calling on the Government to adopt the recommendation of the Joint Committee on Social Protection (in its pre-legislative scrutiny report) that there be a two-year lead-in period, following the relevant legislation being signed into law, that allows businesses time to adequately prepare for the implementation of auto enrolment. In addition to the above, the policy team re-emphasised the Institute’s position that any new scheme of auto-enrolment should facilitate the existing and well established model of tax relief at both standard and marginal rates for pension contributions, rather than introduce a new scheme of tax relief, as proposed.