The Department of Finance and the Department of Public Expenditure and Reform have published the Fiscal Monitor for April 2025 which confirms an exchequer surplus of €2.8 billion to the end of April. This compares to a deficit of €1.2 billion recorded for the same period last year. Tax receipts collected to the end of April were €28.6 billion, which was €3.8 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 €26.8 billion, an increase of €2.1 billion from the same period in 2024. Income tax receipts for the month of April were €3.5 billion which was €0.2 billion ahead of April 2024 receipts. On a year-to-date basis, receipts to the end of April of €11.7 billion were up by €0.5 billion (4.8 per cent), when compared to April 2024. As noted in the Fiscal Monitor, April is not a significant month for corporation tax receipts; receipts of €0.1 billion were collected in the month. On a cumulative basis, receipts of €4.9 billion were up by €2.2 billion on the same period last year. When the once-off CJEU receipts are excluded, cumulative corporation tax receipts to April 2025 amounted to €3.2 billion, ahead of the same period last year by €0.5 billion. April is a non-VAT due month and receipts in the month of €0.3 billion were down slightly on the same month last year by €38 million. Cumulative receipts of €7.9 billion were ahead by 6 percent on end-April last year.

Revenue has published new guidance on the participation exemption for certain foreign distributions which was introduced by Finance Act 2024. The participation exemption applies where a relevant subsidiary makes a relevant distribution on or after 1 January 2025 to a parent company of the relevant subsidiary. The conditions which the parent company must satisfy to claim the exemption, including the required qualifying participation in a relevant subsidiary, are detailed in the guidance. The qualification requirements for a relevant subsidiary are also outlined. A qualifying distribution must be recognised as income in the hands of the recipient for the purposes of corporation tax and it must be made out of the profits or the assets of the relevant subsidiary. The exemption is supplemental to the existing “tax plus credit” approach. Companies must elect to claim the exemption with all qualifying distributions, in that accounting period, being exempt if an election is made. A claim for the exemption cannot be made on a per dividend/distribution or per subsidiary basis.

The Department of Finance and the Department of Public Expenditure and Reform have jointly published the Annual Progress Report 2025 which incorporates the Department of Finance’s spring forecast. The report is a European legal requirement which assesses progress on the implementation of the Government’s Medium-Term Fiscal and Structural Plan. It replaces the annual Stability Programme Updates and the annual National Reform Programme in the EU budgetary cycle. The report outlines that Modified Domestic Demand (MDD) is projected to expand by 2.5 percent in 2025 and 2.75 percent next year, both of which are downward revisions compared to the autumn forecasts. The projections are prepared on the assumption that transatlantic tariffs will not be introduced and forecast a general government surplus of €8.7 billion. In an alternative scenario, which incorporates the likely economic impacts of the tariffs that are now in place, projected MDD growth is lowered to just over 2 percent this year and 1.75 percent next year. The report notes that while the economy, in aggregate terms, is undoubtedly in a strong position at present, the near-term outlook for the Irish economy is clouded in considerable uncertainty. Uncertainty in terms of trade policy, financial and commodity market developments, geopolitics and macroeconomic policies are noted as the dominant features of Irish and global economies. Navigating the challenging external environment is identified as a key priority by this Government. Commenting on the publication, Minister for Finance, Paschal Donohoe said: “The more contested and fragmented world that is now taking shape represents a serious headwind for the Irish economy which has benefited so much from the rules-based, multilateral trade system. Given the elevated level of uncertainty, it is important to stress that our assessment published today is more akin to a scenario analysis; my officials will, of course, continue to monitor incoming data and developments and update numbers accordingly.”

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. The latest minutes and slides from the most recent meeting of the HMRC Northern Ireland Joint Customs Consultative Committee, which the Institute participates in, have been published. Miscellaneous guidance updates and publications Data Element 2/3: Documents and Other Reference Codes (National) of the Customs Declaration Service (CDS), Data Element 2/3: Document and Other Reference Codes: Licence Types — Imports and Exports of the Customs Declaration Service (CDS), Internal temporary storage facilities (ITSFs) 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, Designated export place (DEP) codes for Data Element 5/23 of the Customs Declaration Service, Check if a business holds Authorised Economic Operator status, Claim back an import security deposit or guarantee, and Apply for Designated Export Place approval.

On 19 May 2025 the European Parliament’s HOUS Committee and FISC Subcommittee will host a joint public hearing on the impact of tax policies on the housing crisis in the EU. The public hearing will explore the link between taxation and affordability and how tax policies can shape access to housing in the EU. It will also consider how tax policies can contribute to rebalancing the housing market.

In this week’s miscellaneous updates, the latest Stakeholder Digest from HMRC confirms that it’s new Permanent Secretary and CEO has taken up his office and the expected reductions in HMRC’s interest rates have been announced after the Bank of England Monetary Policy Committee reduced the base rate last week from 4.5 percent to 4.25 percent. The first changes in four years have been made to HMRC’s CEST (check employment status for tax) tool and HMRC has updated their genuine communication guidance to add information about ongoing research into agent and professional standards which means that some tax agents may receive an email or phone call from HMRC inviting them to participate. The latest newsletter from the Federation of Small Businesses (FSB) says that the ‘taxi tax’ must be stopped and small business employers are invited to take part in FSB’s latest survey on the National Living Wage by 19 May. And finally, the Public Accounts Committee (PAC) has published a report on the cost of the tax system which not surprisingly concludes that the cost of administering taxes is increasing for HMRC and taxpayers. New HMRC Permanent Secretary and CEO After the retirement last month of Sir Jim Harra, John Paul (JP) Marks joined HMRC as its new First Permanent Secretary and Chief Executive. JP has been a civil servant for over two decades and previously served as Permanent Secretary of the Scottish Government for three years. In a You Tube video to mark the occasion, JP introduces himself and sets out his key priorities. CEST updated On 30 April 2025 HMRC updated this tool which is used to find out if a worker on a specific engagement should be classed as employed or self-employed for tax purposes. According to HMRC, CEST has been updated to simplify its language; useful links have also been added. The update also features a  new mutuality of obligation question (the obligation on the employer to provide work and the employee to accept the work) which is often key to many decisions at tax tribunal. HMRC has reaffirmed its ongoing commitment to the tool saying it will stand ‘behind the outcomes of this tool where it has been used correctly.’ Updated guidance is therefore expected to be published on how to answer the questions in the tool which have changed. PAC reports on cost of the tax system The House of Commons PAC report on the cost of the tax system concludes that the cost of administering taxes is increasing for HMRC and taxpayers and as a result calls for HMRC to “publish realistic plans to simplify the tax system and establish robust metrics for reporting the impact on its costs, and on taxpayers’ costs, in its annual reports”. The report also says that taxpayers’ trust in HMRC is falling and recommends that HMRC should work with taxpayers and their representatives to understand why this is the case and what it can do to quickly address the decline. HMRC should publish the concerns it has heard and the actions it is taking to address these, as a first step to improving trust.

The Economic and Financial Affairs Council (ECOFIN) will meet on 13 May 2025. At the meeting, the group will be invited to reach a general approach on the directive on VAT rules for distance sales of imported goods and import VAT. The draft directive seeks to improve the collection of VAT on imported goods by making suppliers liable for the VAT paid on import.

HMRC has contacted us to advise that as of 6 May, Unique Taxpayer References (UTRs) are no longer being provided when requested by either agents or taxpayers over the phone. This change is being made for security reasons.   HMRC has asked us to remind taxpayers that they can source this information from the top of the home page of their Personal Tax Account (PTA). If they do not have a PTA, they can find their UTR at the top of any Self-Assessment letter HMRC may have sent. If neither of these methods is available, HMRC will instead send this to them by post after they have successfully answered a series of security questions.   Agents that call on behalf of their client will also be advised of where the client’s UTR can be found. If it’s not possible to retrieve the UTR from one of those sources, then HMRC will issue a letter direct to the agent’s client. This can take up to two weeks to arrive.    

That’s according to the Institute’s Northern Ireland Tax Committee chaired by Janette Burns. The Committee responded last week to the UK Government’s consultation ‘Electronic invoicing: promoting e-invoicing across UK businesses and the public sector’. A series of recommendations featured in the submission including the need to ensure that businesses in Northern Ireland (NI) are not subject to different standards compared to the rest of the UK. Any UK e-invoicing regime should be decentralised and should also be aligned with what is ultimately agreed at EU-level in respect of the Digital Reporting Requirement (DRR) aspect of the VAT in the Digital Age (ViDA) package. The submission also considers the impact on smaller businesses and recommends that grants/tax incentives be introduced to encourage and help fund voluntary uptake. In summary, the key recommendations are as follows: An appropriate lead-in time and extensive testing by and consultation with various stakeholders will be essential in order to successfully implement a UK wide e-invoicing policy, This should begin by encouraging a voluntary approach, in particular for small and micro businesses, by educating taxpayers on the advantages cited in the consultation and by providing grant incentives/tax reliefs to encourage and help fund uptake, Mandatory e-invoicing and real-time reporting should only be introduced in a phased format based on the size of the business, The Government should establish a dedicated e-invoicing support team, A review should be undertaken of the UK’s VAT regime to identify opportunities for simplification ahead of introducing any e-invoicing policy in the UK, Any UK wide e-invoicing system will need to consider the potential impact in the NI context in order to avoid adding further complexity or different standards for different regions within the UK, The UK’s e-invoicing regime should be decentralised and should be aligned with what is ultimately agreed at EU-level in respect of the DRR aspect of ViDA, and Continued open, transparent and broad consultation will be needed with stakeholders to resolve and identify challenges/issues on the journey to a UK wide e-invoicing policy.

The OECD has published its consolidated commentary on Pillar Two. This consolidated commentary incorporates agreed administrative guidance which was released by the Inclusive Framework from March 2022 to March 2025. It also includes guidance on the interpretation and application of the GloBE rules.

Artificial intelligence is rapidly becoming an integral part of daily life, but many organisations have yet to fully grasp its potential, limitations and associated risks, writes David O’Sullivan The introduction of the European Union’s Artificial Intelligence (AI) Act means organisations are now legally required to ensure that employees using AI, as well as those impacted by its outputs, possess adequate AI literacy. AI literacy is the ability to understand, evaluate and interact effectively with AI systems. It encompasses recognising risks and opportunities, interpreting AI outputs and making informed deployment decisions. Ensuring AI literacy within an organisation isn’t just about compliance – it reduces risk, fosters innovation and drives competitive advantage. For businesses seeking to enhance their AI literacy, the European Commission offers detailed guidance, accessible in their online library: AI Literacy Learning Repository. Leading organisations integrate AI literacy into AI governance frameworks, ensuring clear roles, responsibilities and key performance indicators. Here are the six most effective strategies. 1. Tailored training for different levels of expertise A one-size-fits-all approach to training rarely works. Successful organisations provide: Foundational courses for employees new to AI; and Advanced technical training for developers and data scientists. 2. Hands-on learning with practical applications The best way to understand AI is to use it. Companies should offer their employees: Workshops, case studies and simulations to demonstrate AI’s practical impact; and AI sandbox environments for employees to test and experiment with AI safely. 3. Role-specific AI training Different teams utilise AI in different ways. Finance teams, product managers and engineers all interact with AI in various ways. Tailored training can help to ensure employees receive the relevant knowledge necessary to integrate AI into their workflows effectively. 4. AI mentorship and cross-department collaboration Encouraging knowledge-sharing between AI experts and employees helps bridge skill gaps. Some companies establish AI mentorship programmes where experienced employees guide their peers in AI adoption. 5. Embedding responsible and ethical AI practices Many organisations are integrating responsible AI principles into their training, focusing on transparency, fairness and compliance with AI regulations such as the EU AI Act. In Ireland, the Government introduced principles for public sector organisations early in 2024, and these are still relevant today. 6. Continuous learning AI is evolving rapidly. Training should be ongoing with regular updates and refresher sessions to keep pace with advancements. The impact of AI literacy When AI literacy programmes are effectively implemented, organisations experience significant benefits, including: Increased AI adoption and engagement: Companies have seen an increase in employee participation in AI training and a higher usage of AI tools in daily tasks. According to the AI Literacy Learning Repository, one organisation that implemented an AI literacy programme reported a 30 percent increase in AI training participation and a 65 percent rise in AI tool utilisation. Improved workforce confidence and innovation: Employees who are comfortable with AI use it effectively, leading to better decision-making and new ideas. Operational efficiency gains: AI literacy helps automate repetitive tasks, streamline workflows and boost productivity. New AI-driven offerings: Some organisations have leveraged AI literacy training to upskill employees, leading to new AI-driven products and services. Greater consumer trust: Companies that prioritise transparency in AI usage – and educate affected individuals – see higher trust levels. Some businesses even involve clients in AI training sessions. Making AI literacy a business priority Organisations cannot afford to overlook AI literacy, given our rapidly changing world and the requirements of the EU AI Act. Investing in education, practical training and ethical AI practices equips employees with the skills they need to work effectively with AI and allows leadership to make informed decisions on deployment and controls. By addressing challenges and leveraging the best strategies, companies can build an AI-literate workforce that drives innovation, enhances efficiency and ensures responsible AI use while meeting compliance objectives. AI literacy isn’t just about understanding how AI works; it’s about ensuring businesses and employees can utilise AI effectively to create meaningful and positive outcomes. If your organisation hasn’t yet prioritised AI literacy, now is the time to start. David O’Sullivan is Director of Privacy, Digital Trust & AI Governance at Forvis Mazars

Under the new Small-Scale Renewable Electricity Support Scheme, SMEs can turn idle rooftops or land into a 15-year income by exporting renewable electricity, writes Justin Wallace The recently launched Small-Scale Renewable Electricity Support Scheme (SRESS) presents a valuable opportunity for small- and medium-sized enterprises (SMEs) that may have under-utilised rooftop space or land available for long-term passive income. SRESS is an initiative of the Department of the Environment, Climate and Communications, designed to support SMEs, farmers and communities that wish to generate renewable electricity for export to the national grid. It offers support for solar photovoltaic (PV) and onshore wind renewable electricity installations that are not suitable for the larger utility-scale Renewable Electricity Support Scheme (RESS) or the Micro-generation Support Scheme (MSS). Support is offered in the form of a guaranteed tariff for 15 years to export projects ranging in capacity from 50 kw to 6 MW. The scheme opened for applications in January 2025. When a business joins the SRESS scheme, it receives payment through a Power Purchase Agreement (PPA) with a supplier, utilising a special payment system designed to provide certainty to SRESS projects, thereby insulating it from fluctuating market prices. Regardless of the market reference price of electricity, businesses will receive the same amount for the power supplied. When electricity prices are low, the payment received from a supplier is topped up. Conversely, when prices are high, SMEs still receive the standard tariff rate, but their supplier separately pays a surplus into a Government fund, the Public Service Obligation (PSO) levy. This scheme presents a valuable opportunity for SMEs that may have under-utilised rooftop space or land. For instance, a 50 kilowatt peak (kWp) rooftop or ground-mounted installation requires only 125 to 200 solar panels, equivalent to 250 to 300 square metres of roof space, roughly the size of a double tennis court. The SME tariff for solar projects under 1 megawatt (MWh) is €130/MWh (€0.13/kWh), which generates a passive yearly income for your business for 15 years. Further, solar panels are low-maintenance and generally expected to last for 25 to 30 years, so your system should still be capable of generating renewable electricity even after the SRESS support period ends. This could involve entering into a new PPA, without Government support, but with capital costs paid off. If you are interested in joining SRESS, start by assessing your premises to determine its suitability for a renewable energy project. Consider how close your premises is to a grid connection at an ESB substation. Generally, being located closer to a substation brings down the cost of your connection. ESB Networks publishes capacity heatmaps, which indicate the spare transformer capacity available at substations at each voltage level. For generators exceeding 200 kilowatt (kW), ESB Networks provides a minimum cost calculator tool to estimate the minimum costs associated with connecting to the grid. Visit the grid cost calculator tool and grid capacity map on the Department’s website for more information. Consider engaging a renewable energy expert to assist with calculating the financial implications, risk assessment and negotiating agreements. They can assist with estimating the total upfront costs, including equipment, installation, grid connection and other fees, as well as ongoing operational and maintenance costs. A renewable energy expert can also calculate the expected revenue of the project based on the tariff rate and projected energy generation, taking into account variables such as seasonal change and any potential downtime. Generally, most renewable electricity projects are required to have full planning permission in place before applying to SRESS. However, revised regulations, introduced in October 2022, expanded the eligibility of properties for exemptions to include the rooftops of certain premises, such as industrial buildings and businesses. While these exemptions are subject to certain conditions and limitations, your local planning authority will be able to confirm if your premises is eligible for such an exemption. Further information and details on the solar planning exemptions are available on the Department of Housing, Local Government and Heritage’s website. If pursuing an export project is not for you, there are also grants available for renewables self-consumers with projects from 50 kw up to 1 MW under SEAI’s Non-Domestic Microgen Grant. Renewable energy self-consumers are electricity customers who generate their own renewable energy for personal use. They may then sell or store any excess electricity produced, if electricity generation is not their primary business. To apply for SRESS, applicants must complete the application form. Completed application forms and any additional queries relating to the scheme can be directed to sress@decc.gov.ie. SRESS will ultimately contribute to lower long-term energy costs for both households and businesses, enabling them to play a key part in the renewable energy transition. Please see the scheme’s T&Cs and its Non-Technical Summary for more information. Justice Wallace is an Officer in the Department of the Environment, Climate and Communications