In this week’s post EU exit corner, we bring you the latest guidance updates and publications relevant in the post EU exit environment. The most recent Trader Support Service bulletin is also available as is the latest Brexit and Beyond newsletter from the Northern Ireland Assembly EU Affairs team. Miscellaneous guidance updates and publications Internal temporary storage facilities (ITSFs) codes for Data Element 5/23 of the Customs Declaration Service, Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service, Reference documents for The Customs (Reliefs from a Liability to Import Duty and Miscellaneous Amendments) (EU Exit) Regulations 2020, 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 Importing SPS controlled goods that interact with the ALVS, Check if a business holds Authorised Economic Operator status, List of customs training providers, and Using commodity codes and related additional codes in the Customs Declaration Service.

Revenue has launched a new Customer Charter which outlines the principles for service delivery and the mutual expectations in dealings between Revenue and its customers. The Charter emphasises that Revenue’s primary service delivery channel is digital and outlines that the digital self-service channels process millions of customer transactions annually. Revenue recognises that some customers may, due to their personal circumstances, have difficulty in using the digital services and that a network of trained Access Officers is available to assist persons with a disability in accessing services provided by Revenue. Revenue will also provide virtual and in-person appointments where necessary. The Charter affirms the commitment by Revenue to transparent accountability, including the publication of regular performance reports on service delivery.

The Institute, under the auspices of the CCAB-I, made representations on behalf of members at recent meetings of the Tax Administration Liaison Committee (TALC) Direct and Capital Subcommittee and TALC Indirect Taxes Subcommittee. Among the issues that the Institute raised were the filing requirements for Investment Limited Partnerships and the VAT treatment of microgeneration of electricity. TALC Direct and Capital Subcommittee meeting Filing requirements of an Investment Limited Partnership CCAB-I raised a query on the filing requirements for Investment Limited Partnerships (ILPs). An  ILP is regulated by the Central Bank of Ireland as a Qualifying Investor Alternative Investment Fund (QIAIF). The partners of an ILP are similar to shareholders in an investment company or unitholders in a unit trust. Section 739J(3) TCA 1997 requires an ILP to file a return on or before 28 February in the year following the year of assessment. This is known as the Form ILP1. Our members were reporting confusion as to whether an ILP is also required to file the Form 1 (Firms) partnership return. In our view, a Form ILP1 should be the appropriate form. Revenue confirmed, however, that an Investment Limited Partnership is required to complete both a Form 1 (Firms) and a Form ILP1. A new tax and duty manual on partnerships will issue in the coming months. Partnerships and association for the purposes of certain ATAD measures CCAB-I raised a query on the meaning of “associated entities” and the impact on partnerships for the purposes of the Outbound Payments Defensive Measures. This concept is also discussed in guidance on Anti-Hybrid Mismatches and on the Interest Limitation Rule. We requested clarification on whether guidance in the latter manuals pertaining to partnerships would be updated to reflect the guidance in the Outbound Payments Defensive Measures manual. Revenue noted that future guidance will cover the general tax implications of partnerships and specific provisions which should address the query raised. Residential Zoned Land Tax An update was provided by Revenue on the recent meeting of the Residential Zoned Land Tax Subcommittee. The issue regarding the lack of a clearance mechanism for certain property transactions was raised and consequent expected delays were outlined to Revenue. TALC Indirect Subcommittee meeting VAT on the microgeneration of electricity Revenue confirmed that the application of VAT on the microgeneration of electricity by businesses can be managed by the business itself or by the electricity supplier receiving the excess energy via customer self-billing. VAT in the Digital Age update Revenue also outlined the measures which form part of the VAT in the Digital Age (ViDA) proposal which aims to significantly modernise the EU’s VAT system. The three pillars to the proposal cover e-invoicing and digital reporting, platform economy, and single VAT registration with all proposals expected to be fully implemented by 2030. VAT scheme for small enterprises Revenue confirmed that the directive on the special VAT scheme for small enterprises (Directive 2020/285) will be transposed soon, after which guidance will be issued. This scheme is operating by Revenue on an administrative basis since 1 January 2025.

The Department of Finance and the Department of Public Expenditure and Reform have published the Fiscal Monitor for February 2025 which confirms an exchequer surplus of €3.2 billion to the end of February. This compares to a deficit of €0.1 billion recorded for the same period last year. Tax receipts collected to the end of February were €15.2 billion, which was €3.2 billion ahead of the same period last year. 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 €13.5 billion, an increase of €1.5 billion. Tax revenues of €5.1 billion were collected in the month of February, up by €0.9 billion on the same month in 2024. Income tax receipts of €2.7 billion were recorded in the month of February, €0.2 billion ahead of last year.  On a cumulative basis, income tax receipts of €5.7 billion were €0.3 billion (5.8 per cent) ahead of the same period in 2024. Corporation tax receipts of €1.0 billion were collected in the month which was an increase on February 2024 by just under €0.5 billion, mainly due to a once off amount not related to the CJEU ruling. On a cumulative basis, receipts of €2.8 billion were up by €2.2 billion. When once-off CJEU revenues are excluded, cumulative corporation tax receipts to the end of February 2025 amounted to €1.1 billion, ahead of the same period last year by €0.5 billion. February is not a VAT-due month and modest receipts of €0.5 billion were collected in the month, up by €0.1 billion on February 2024. Cumulatively, VAT receipts of €4.6 billion are ahead of the same period last year by €0.3 billion. Excise duty receipts of €0.5 billion were collected in February, up by €43 million on the same month last year. Commenting on the figures, Minister for Finance, Paschal Donohoe said ”February is not generally a significant month for tax revenues, but the steady performance across most tax heads to date is a further positive reflection of the strength of our economy. The March returns, which incorporate the first large corporate tax payments of the year, will provide a clearer indicator of the performance of the public finances. In an increasingly uncertain global environment, it is now more important than ever that we maintain our public finances on a positive trajectory. This Government is committed to doing this in a balanced and sustainable way.”  

The Directorate-General for Taxation and Customs Union has announced the release of updated Guidance on the Preferential Rules of Origin. The updated guidance is intended to enhance clarity and compliance in international trade.

The OECD has released the latest BEPS Action 14 Mutual Agreement Procedure (MAP) peer review results which indicate ongoing progress in making dispute resolution more effective. Jurisdictions have committed to implementing the minimum standard for treaty-related disputes under the BEPS package.

The OECD will host its virtual Tax and Development Days 2025 event later this week. This event provides an update on OECD initiatives to strengthen tax capacity, enhance tax policy, and improve compliance in developing countries, while also exploring future challenges.

On 18 March 2025, the European Parliament and the European Commission will co-host the third edition of the EU Tax Symposium. This year, the event will take place under the theme: Strengthening competitiveness and fairness to build prosperity.

IAASA has published its 2024 quality assurance review reports in respect of seven firms that perform statutory audits of public-interest entities (PIEs) in Ireland. The reports summarise IAASA’s inspection of each firm’s internal system of quality management. The reports include any findings and recommendations made by IAASA to the firms regarding these systems. The reports also summarise the results arising from IAASA’s inspection of a sample of audits of public-interest entities performed by each firm, including the grades assigned to the audits inspected and any key recommendations made to the firm.

Technical Alert 02/2025 – Illustrative Management Representation Letter in respect to the provision of Limited Assurance under the Corporate Sustainability Reporting Directive This Technical Alert provides an illustrative example of a management representation letter that may be used by the assurance provider when conducting a limited assurance engagement required under the Corporate Sustainability Reporting Directive (“CSRD”) as transposed in Ireland into Part 28 of the Companies Act 2014. The International Standard on Assurance Engagements (Ireland) 3000 Assurance Engagements Other Than Audits or Reviews of Historical Financial Information – Assurance of Sustainability Reporting in Ireland (ISAE (Ireland) 3000) as issued by the Irish Auditing and Accounting Supervisory Authority is the applicable assurance standard to be used for CSRD sustainability reporting in Ireland. ISAE (Ireland) 3000 paragraph 56-57 provides that: “56. The practitioner shall request from the appropriate party(ies) a written representation: That it has provided the practitioner with all information of which the appropriate party(ies) is aware that is relevant to the engagement. Confirming the measurement or evaluation of the underlying subject matter against the applicable criteria, including that all relevant matters are reflected in the subject matter information. 57. If, in addition to required representations, the practitioner determines that it is necessary to obtain one or more written representations to support other evidence relevant to the subject matter information, the practitioner shall request such other written representations.”   Click here  to access the TA.  Click ISAE (Ireland) 3000 to access the standard.

In every issue of The Bottom Line, we ask students for their thoughts on a particular topic. This month, we want to know: How do you feel about the state of the world in 2025? Alisha Mullins Deloitte In 2025, I find myself reflecting on the state of the world with a sense of both optimism and concern.  On the one hand, technology has brought incredible advancements, from artificial intelligence to sustainability efforts, offering potential solutions to many global challenges. The world is more connected than ever, allowing for cross-border collaboration and the sharing of ideas.  On the other hand, issues such as economic inequality, climate change and political instability remain daunting.  As we move forward, we need to keep a strong focus on making decisions that are not only smart but also ethical and responsible.  For those of us starting our careers, especially in fields like accounting, we have a chance to help shape a world that balances progress with fairness.  It’s an exciting time, but we’ve got a lot of work ahead to make sure the future is a good one for everyone. Shaun Towlson EY Looking at the state of the world in 2025, the mortgage crisis in Ireland stands out as a real concern.  Even though the country has bounced back since the 2008 crash, high property prices and rising interest rates are still making it hard for first-time buyers to get onto the property ladder. Many people are stuck paying high rents with little chance of owning a home.  For those who do own, rising mortgage payments are adding more stress, especially with the cost of living going up.  As an accounting student, I can’t help but see how this affects not just individuals but the economy as a whole. It’s clear that we need better policies and responsible lending to create a housing market that works for everyone—not just the lucky few.  It’s a tough situation, but it’s also an opportunity to learn from the past and make meaningful changes. Niamh McLoughlin  Deloitte As we’re in 2025, climate action feels more urgent than ever.  The reality of climate change is hitting harder now, with extreme weather, rising sea levels and the growing toll on ecosystems.  While there’s been some progress with renewable energy and sustainability efforts, it often feels like it’s not enough.  As an accounting student, I see how important it is for us in the financial world to push for real change—whether it’s supporting green initiatives or advocating for better reporting on environmental impacts.  The business world has a big role to play, and it’s on all of us to ensure that sustainability isn’t just a buzzword but something we actively work toward.  We need to move faster, make smarter decisions and think about how our actions today will impact the planet tomorrow. The time to act is now.    

Jumping straight into a commercial role after qualifying is tough, but there’s a smarter way to get there. Understanding financial accounting first can set you up for success. Heather Gordon explains why it’s worth considering A lot of newly qualified accountants want a “commercial” or “business partnering role” as their first step from practice into industry. The catch? Only about five percent of roles for newly qualified accountants are purely commercial. And, wow, are those hard to get straight out of contract!   But we get it; you’ve just qualified and want to do something different, something commercial, where you can make impactful decisions. That makes sense. Continuum of activity Let’s take a step back and understand the options available to you at the end of your training contract and why it might be a good idea to pursue a financial accounting role first.   Figure 1 below is what we call the continuum of activity. It is a simple visual to help you map out the activity in a basic finance team and understand the context of the roles you will look at after you qualify.  Purely commercial roles sit on the very far end of this spectrum, influencing how a company makes and spends money. To get access to these roles and excel in them, it’s a good idea to spend some time understanding how the business works, how it makes money and the nature of the various stakeholders.  Without knowledge and experience in these areas, your opinion will carry little weight, ability to influence will be negligible and you’ll lose credibility fast.  The good news is that you can partner with the business and get involved in decision-making without having to jump straight into a “commercial” role. How? Here are a couple of things you should consider about a financial accounting role: “Financial accounting” can mean different things in different organisations. However, it is not audit or pure technical accounting – make sure you put those roles in different buckets.  Spending time putting together a profit and loss statement (P&L) and analysing it is priceless if you want to learn how a business makes and spends money. The work is dramatically different from auditing and can be a breath of fresh air for many. In financial accounting, you partner with the business. Business leaders live and die by their P&L; ultimately, you will partner with them to deliver their business results. In financial accounting, you might not get to make decisions about the business directly, but you’ll have plenty of chances to make decisions about the “business of finance”. New reporting formats/visuals, processes and systems are all ways in which you can get directly involved in making decisions for finance in the business. Beyond the job title When you want to move into a commercial role, consider more than just the job itself. Here are some important points to think about before making the switch. Organisation size  Think of the continuum like a coiled spring—collapse it down for a smaller business/entity, and one person does everything.  Expand it for a larger business, and specialisation emerges in various areas such as tax, statistical reporting and technical accounting.  Why does this change? With size comes complexity. Organisational structure The nature of financial accounting activity and how much of the continuum it covers will often be a manifestation of the organisational structure (group function vs shared services sector vs small and medium enterprise, for example).  Job titles mean nothing without context, and every financial accountant role will be subtly different depending on the structure in which it sits and the division of labour on the team. Activity balance  The balance of activity in a job specification can be very telling. Job postings list tasks, but they rarely give those tasks a weighting of time. This continuum can be very useful when reviewing job specs and understanding what the role you are going for actually involves.  Smart accountants don’t get caught up in buzzwords but look beyond the job title to the context of the role. They look at their careers in a structured way and earn the right to an opinion in a business before giving one.