HMRC has recently updated the Making Tax Digital (MTD) for income tax taxpayer and agent sign up guidance pages to reflect changes to the eligibility criteria for participating in the MTD for income tax trial in 2025/26. Following these changes, taxpayers reporting the high income child benefit charge and/or income from a jointly owned property will be able to sign up voluntarily to join the MTD for Income Tax 2025/26 trial phase ahead of mandation for the first phase of taxpayers with turnover exceeding £50,000 from April 2026. Further updates on the 2025/26 testing phase are expected ahead of its launch which is currently targeted for April 2025.

In this week’s miscellaneous updates, HMRC has confirmed that its interest rates will be reduced after the recent Bank of England base rate reduction and a consultation is taking place on HMRC statistics. From April 2025, the legislation which gives effect to the UK-Russia and UK-Belarus Double Taxation Treaties in UK law will be revoked and HMRC’s Guidelines for Compliance (GfC) have published the latest GfC on labour supply chain assurance. 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. HMRC late payment interest rates to be reduced HMRC has confirmed that its interest rates for late payments will be revised and reduced by 0.25 percent following the Bank of England interest rate cut to 4.5 percent. These changes will come into effect on: 17 February 2025 for quarterly instalment payments, and 25 February 2025 for non-quarterly instalments payments. HMRC’s information on the interest rates for payments will be updated shortly. Consultation on changes to HMRC statistics publications On 16 January 2025, HMRC published a consultation seeking views on how the statistics they publish are used. HMRC recognises that it is important to engage with statistical publication users regularly and to consider whether publications remain of high value to them. The aim of the proposals is to ensure that HMRC: continues to produce useful and relevant statistics for use by its stakeholders, adding to its existing statistics where appropriate, and adapts statistics publications to reduce what is produced for those which are no longer widely used, are duplicated elsewhere, or could be produced less frequently. The consultation closes on 10 April 2025. Revocation of UK-Russia/Belarus tax treaties Following Russia’s unlawful action to suspend material provisions of the 1994 UK-Russia Double Taxation Convention and the 2017 UK-Belarus Double Taxation Convention, the UK continued to honour its treaty obligations. The UK requested that Russia come back into compliance with its international legal obligations. However, as it did not do so, the UK has now notified Russia of its intention to suspend the Convention. The UK will therefore revoke the legislation which gives effect to these conventions in UK law. These will both cease to have effect from: 6 April 2025 for Income Tax and Capital Gains Tax, and 1 April 2025 for Corporation Tax. The UK will continue to honour its obligations under the treaties until these dates. However, thereafter, there will be an increased risk of double taxation, with a need to rely on the relief (if any) available under domestic law noting the potential for this to be restricted by ongoing sanctions. The following publications have therefore been updated: Belarus: tax treaties, and Russia: tax treaties. New GfC on labour supply chain assurance HMRC’s GfC team has published Help with labour supply chain assurance — GfC12. The guidelines are designed for larger organisations in the top tiers of a labour supply chain; however, the principles can be applied to most businesses. HMRC continues to tackle tax defaulters in labour supply chains directly. Many risks arise where there are opportunities to exploit larger, higher value, and more complex chains. HMRC is concerned about how these risks can affect a business’s own tax affairs. These guidelines explain how taxpayers can self-assess their own assurance practices and aim to help taxpayers identify and limit the impact of risks. The guidelines: explain what labour supply chains are and the associated risks, promote the importance of effective labour supply chain assurance, and provide practical advice to consider when carrying out labour supply chain assurance. These have been produced using a different format than previous guidelines hence HMRC is keen to hear feedback on the new format. If you have any queries or feedback, please contact the GfC Mailbox. Alternatively, there is an anonymous survey in the Next steps, further questions and feedback section.

Revenue has updated the Tax and Duty Manual Guidance on the Residential Zoned Land Tax (RZLT) to reflect Finance Act 2024. The main changes to the manual reflect amendments to the sections dealing with land subject to the RZLT, administration, exemptions, deferrals and abatements and other issues.

The Commission’s priorities on tax matters were outlined in a recent address to the European Parliament’s tax matters subcommittee. Commissioner Hoekstra said that simplifying and fraud-proofing the EU’s tax laws, further reforming VAT rules, favouring renewable energy through tax policy, and better addressing the tax gap would be some of his main priorities. The Commissioner also confirmed that he will look for opportunities to engage constructively on Pillars One and Two with the US Administration in light of the recent US executive order on the OECD global tax deal.

Last week Revenue published statistics relating to 2024 PAYE tax returns filed to date this year on the back of which PAYE taxpayers are being encouraged to use the myAccount service to finalise their tax position. The statistics showed that as at 29 January 2025, over 550,000 PAYE returns had been processed for 2024 which resulted in refunds of over €400 million to PAYE taxpayers. Revenue is reporting a continuing increasing trend in the use of Revenue’s my Account service to file tax returns. An underpayment of tax arose in approximately 12 percent of the returns processed and Revenue has advised that they will engage with the relevant taxpayers to collect the tax due by reducing tax credits over a four-year period. Revenue has reported they estimate a further €389 million of tax may have been overpaid by PAYE taxpayers in 2024. In light of this, Revenue has launched a campaign to encourage PAYE taxpayers to use the myAccount service to finalise their tax position. Revenue has provided details on how to access this service and detailed guidance on submitting a PAYE tax return and claiming tax credits and reliefs.

At a recent public meeting hosted by the FISC subcommittee on tax matters, experts discussed ‘A coherent tax framework for the EU’s financial sector’. The forum considered innovative solutions for the taxation of the EU's financial sector to further integration, facilitate cross-border operations and foster digitalisation and innovation. The hearing also considered the challenges stemming from the current VAT exemption for financial services.

In this week’s post EU exit corner, we bring you the latest guidance updates and publications relevant to 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. Bookings are now open for a HMRC webinar next week on the new arrangements for the movement of parcels and freight between Great Britain and Northern Ireland which commence from 31 March 2025, delayed from 30 September 2024. For more information, click read more. HMRC webinar on new arrangement for parcels and freight The Windsor Framework establishes a new set of arrangements for the movement of goods between Great Britain and Northern Ireland via both parcels and freight. HMRC has organised a free webinar on Monday 24 February 2025 from 2-3pm to help businesses that make parcel movements between Great Britain and Northern Ireland prepare for the new arrangements by 31 March 2025. HMRC is encouraging interested parties to sign up. This webinar follows on from the webinar held on 21 November 2024, which you can view the recording of on the newly launched WF resource page. On the day, the webinar will cover:  What the new parcel arrangements are, The UK Internal Market Scheme (UKIMS) and how to send business to business parcels under UKIMS, Illustrative parcel journeys for consumer and business parcel movements, and A Q&A slot. To register and pre-submit any questions, please click this link. You are also reminded to save the invite to your calendar once registered. Miscellaneous guidance updates and publications Multinational companies and companies based in both GB and NI Economic Operators Registration and Identification (EORI), EORI, Who should register for an EORI number, Place of registration, Finding and checking an EORI, and Location codes for ports of entry in Great Britain.  

The Department of Finance and the Department of Public Expenditure and Reform have published the Fiscal Monitor for January 2025 which confirms an Exchequer surplus of €3.6 billion in January. This compares to a surplus of €2.3 billion recorded for January 2024. Tax receipts collected in January were €10.1 billion, which was €2.3 billion ahead of the same period last year. Excluding the once off receipts arising from the judgement of the Court of Justice of the European Union (CJEU) in the Apple State aid case, total receipts of €8.4 billion were collected in January, ahead by €0.6 billion on the same period last year. Income tax receipts of €3.0 billion were recorded in January, €0.1 billion ahead of January 2024. Although January is not generally a significant month for corporation tax, receipts of €1.8 billion were collected in the month which was an increase on January 2024 by just under €1.8 billion, due almost entirely to once-off receipts arising from the CJEU ruling. January is a VAT-due month and generally the strongest VAT month of the year, encompassing the Christmas trading period. Receipts of €4.1 billion were collected in the month, up by 5.8 percent compared to January 2024. Excise duty receipts of €0.5 billion were collected in January, up by €27 million on the same month last year. Commenting on the figures, Minister for Finance, Paschal Donohoe said “Today’s figures show that tax revenues continued to demonstrate steady growth at the start of the year. In particular, the ongoing expansion of income tax and VAT receipts are a positive indicator of the fundamental strength of our economy. However, there are clear risks ahead. As a small open economy, Ireland is particularly vulnerable to changes in the global economic environment. This underlines the importance of continuing to pursue a balanced and sustainable fiscal policy. That is why Government has committed to using the once-off proceeds from the CJEU decision to improve our stock of infrastructure, as well as investing windfall tax revenues in the Future Ireland Fund to prepare for future challenges.”

The OECD has published the latest peer review results on preferential tax regimes under BEPS Action 5. The results highlight the progress made by jurisdictions in addressing harmful tax practices through the implementation of BEPS Action 5.

The European Commission is seeking feedback on an initiative to provide standard forms and computerised formats to be used in relation to the sixth update to Council Directive 2011/16/EU on administrative cooperation in the field of taxation. The consultation period runs until 4 March 2025.

In his book The Closing of the Auditor’s Mind?, David J. O’Regan, FCA, examines how an erosion of trust in modern auditing might be remedied and reversed. Increasingly fragmented patterns of accountability and social trust are in the ascendant and there are implications for a crucial area of our socio-economic existence—internal auditing. Internal auditing faces not only a challenge of adaptability to emerging patterns of accountability and social trust, it is also confronted by broader challenges of reforms required to encourage such adaptability. One might prefer the term “crises” to “challenges” but let us avoid leavening our analysis with hyperbolic language. Nonetheless, the severity of internal auditing’s two contemporaneous and interconnected challenges discussed is not to be underestimated. Should the challenges remain unaddressed, they may well develop into profound crises. Regarding the first challenge of adaptability, internal auditing has failed to keep pace with global trends toward a flattening of traditional, vertical hierarchies of the command-and-control variety, and their replacement with complex patterns of horizontally distributed accountability and social trust. Our trust in traditional institutions and in politicians, business leaders and the cultural elite is eroding. We are increasingly placing trust in non-hierarchical networks, both digital and human. And where trust has been displaced, flows of accountability adapt accordingly. The emergent patterns of accountability and social trust are so far-reaching that they threaten to leave internal auditing marooned, like a shipwreck, in the detritus of history. Internal auditing is therefore at a crossroads, both practical and conceptual. The most demanding needs of accountability and social trust increasingly fall into three domains – in the inner workings of organisations; in transitional spaces at organisational boundaries; and in extra-mural activities. Internal auditing remains fixated on the innards of traditional, bureaucratic structures and is ill-positioned to address the assurance demands arising at both the liminal spaces at the fringes of formal organisational structures and from locations beyond institutional boundaries. The peripheral and external domains are characterised by an absence of clear markers of responsibilities, and by fast, flexible and disorienting flows of accountability that bear little resemblance to the shape of traditional bureaucracy. Their records of accountability are typically digital rather than tangible, and the significance of their assurance demands defies easy evaluation. Importantly for our analysis in this book, we encounter the new patterns of accountability and social trust where the writ of internal auditing, as well as external auditing, runs weakest. The versatility of both internal and external auditing is hampered by restraints. The external auditor’s opinion on an organisation’s annual financial statements once satisfied the assurance needs of traditional hierarchies of accountability and social trust, but it is ill-equipped to meet the demands of the emergent, horizontally distributed accountability paradigm. In contrast to external auditing, internal auditing’s activities are framed in more elastic terms, and internal auditing therefore offers, on paper at least, a greater scope for adaptation. Yet internal auditing, like external auditing, faces an uncertain future, owing to the need for the types of reform without which the necessary agility and adaptation are unlikely to develop. At this point, a word of caution is in order. Even amid the newly emerging patterns of horizontally distributed accountability, bureaucratic organisations characterised by command-and-control structures will continue to exist. A demand for external and internal auditors’ services will therefore remain, as long as stakeholders continue to be interested in financial statements and in the inner workings of organisations. But the real action on accountability and social trust will increasingly be found elsewhere on the fringes of organisations and in extra-mural locations. Already, assurance is becoming increasingly piecemeal. We can expect the emergence, in the near future, of innovative, diffuse assurance mechanisms to address the pressing demands of the new patterns of accountability and social trust. Both external and internal auditing therefore face a future of marginalisation as they remain shackled to the outdated frameworks of bureaucratic institutions. Internal auditing faces not only a challenge of adaptability. It also contends with a second challenge arising from its increasing tendency toward algorithmic and mechanistic activities. In particular, the dangers arising from a swelling tide of amoral and pedantic literalism in internal auditing are difficult to overstate. A humane approach to internal auditing founded on creativity, individual judgment, and critical thinking. In this context, there is a sense of loss that seems an inevitable accompaniment to progress. Or, perhaps more accurately, an accompaniment to misplaced notions of progress. Internal auditors today have at their disposal vast pools of data, along with powerful technological tools that mine and arrange the data into auditable information. Technological advances encourage internal auditors to approach well-worn topics in fresh ways and to explore newfangled activities. Only a Luddite would be hostile to technological advances in internal auditing, from data analytics to the use of drones for the purposes of aerial surveillance of dispersed inventory. But internal auditing’s technological achievements have come at a high cost – as an addictive substitute for critical thinking. Internal auditors are increasingly gripped by an algorithmic mindset, and they tend to look at technology, not as a means to an end, but as an end in itself. This technologically driven approach has crowded out arduously gained humane aspects of internal auditing. The relentless, metallic clatter of technological advance does not therefore necessarily imply improvements in understandings of underlying concepts. Our collective faith in data analytics and sampling software has created the seductive but dangerous myth that we are better auditors than our predecessors. We seem unaware that accretions of prowess in data handling and number-crunching often offer little more than illusions of certainty, if not groundless uncertainties. The technology of internal auditing may progress, but the cogency of the concepts and principles of internal auditing remain enduring. Diagnostic acumen, analytical rigor, inferential precision, a healthy scepticism, and a resistance to transient faddism are unchanging prerequisites for good internal auditing, and our progressive internal auditing environment now needs them more than ever. Modern internal auditing does not lack energy. However misplaced, its enthusiasm is in constant motion, exuding an exaggerated sense of industriousness. But the blustering, frenetic pace of internal auditing today masks an underlying intellectual inertia, a kind of hallucinatory lassitude in which highly agitated activity serves only to endow clockwork routines with decreasing significance. Beneath whirlwinds of risk assessments, data analytics, and trending buzzwords, and beyond the dubious recommendations that often flow from such mechanisms, we see process increasingly triumphant over substance. It is at internal auditing’s eerily muted core where the absence of timeless concepts of validity and truth are most keenly felt. A technocratic conformity is descending on internal auditing like a smothering shroud, leaving us with muffled reverberations of futile routines, hollow platitudes, and a steady decline in the public’s trust. Only a fundamental overhaul of internal auditing’s self-understanding and methodologies, driven by a tempering of its algorithmic mindset, will open the door to a return to a style of auditing marked by creativity and judgment. Without such an overhaul, internal auditing is unlikely to survive a take-over by automated auditing software and machine-processed artificial intelligence, let alone adapt to the evolving paradigm of accountability and social trust. About the author David J. O’Regan has authored nine books on auditing and related themes. A Fellow of the Institute of Chartered Accountants in England and Wales, he earned a doctorate in accounting and finance from the University of Liverpool and his auditing experience spans more than three decades, in the private, public and academic sectors. O’Regan joined the United Nations system in 2005, working initially at the Organisation for the Prohibition of Chemical Weapons at The Hague in the Netherlands. He has served as Auditor General to the Pan American Health Organization in Washington D.C. since 2009. For more, see davidoregan.com.

The Statement on Internal Control is critical to the effective risk management and governance of Ireland’s State bodies. Tom Ward and Níall Fitzgerald offer their best practice insights Recent challenges faced by Irish entities in the public, non-profit and private sector have emphasised for many boards (and, where relevant, their funding bodies) the critical importance of the adequacy and operational effectiveness of internal controls, risk management and governance. Ultimately, a systematic and proactive approach to testing and reviewing controls, addressing weaknesses and implementing remedial actions in a timely manner, can only enhance confidence in public sector governance and best practice. In this regard, the Statement on Internal Control (SIC) plays a crucial role. State bodies in Ireland are required to report on all of their internal controls, risk management and governance in their annual SIC in accordance with the Irish Code of Practice for the Governance of State Bodies 2016 (Code of Practice).  Such reporting encompasses financial, business, operational and compliance controls and State bodies are subject to a swathe of such controls as standard, spanning: The discharge of public business. Project delivery and cost management. Monitoring and control of assets. Fraud prevention and detection. IT systems and technology (including cybersecurity).  Procurement. Additional controls specific to the nature of each bodies’ activities include clinical governance for public hospitals, infrastructure guidelines for large infrastructural projects and controls relating to onward funding to other public bodies or non-profits. The SIC must acknowledge the Board’s responsibility for ensuring that effective internal control systems are in place, the approach taken to reviewing these systems to ensure they are working (including steps taken by the Board and its Committees) and must identify any significant weaknesses or breaches. While the format for the SIC is prescribed, the content should be tailored according to the size and complexity of the organisation. However, there is limited guidance on the extent to which the Board should tailor this approach and content. At a recent SIC event co-hosted by Chartered Accountants Ireland and the Institute of Public Administration’s Governance Forum, Andy Harkness, from the Comptroller and Auditor General (C&AG) Office, provided examples of SIC best practice for State bodies, including the need for:  Good documentation clearly explaining the work carried out to support the review of controls; Assurance statements provided by senior managers; The involvement of the internal audit team, including key changes arising from their reviews and recommendations; and  If appropriate, an assurance statement from  independent assurance service providers.  Within this approach, the C&AG highlighted the importance of documenting any issues that may arise and adequately supporting any work undertaken to ensure that significant risks have been identified, including risks arising from changes to the control environment. Also emphasised was the importance of assessing the effectiveness of the controls in place, the assurance results and the effectiveness of follow-up steps taken in response to any control deficiencies identified.  Board and board committees should minute their review and conclusions with regard to the effectiveness of the systems of internal controls under review, and record recommended changes to governance, internal controls and risk management matters arising from the review. Also speaking at the recent SIC event, several experienced non-executive directors provided examples of the approaches they have taken to preparing the SIC within their organisation. In particular, they noted challenges associated with the absence of formal guidance and the ambiguity surrounding the term “operating effectiveness”, which is typically associated with Sarbanes–Oxley applying to companies listed on the US Stock Exchange.  In an Anglo-Irish context, assurance on the effectiveness of controls has traditionally been limited to financial and reporting controls. This is, however, changing. To achieve best practice in SIC reporting, the Boards of State bodies in Ireland may currently rely on: Guidance issued by the Financial Reporting Council (FRC) in Britain in relation to the UK Corporate Governance; International Standards on Assurance Engagements (ISAE) 3402 Reports; Sarbanes–Oxley literature for directors and auditors;  Guidance or circulars issued by the Department of Public Expenditure, Infrastructure, Public Services, Reform and Digitalisation or the C&AG; and General assurance standards and guidance. Some best practice insights for State boards arising from the recent SIC event include: The benefit in defining, adopting and communicating a common framework for performing the review of internal controls. The importance of the work needed to support and underpin the SIC. The need to ensure that the findings reported in the SIC are consistent with other supporting documentation approved and minuted by the Board. The need to disclose any scope limitations encountered in the processes necessary to support the SIC and to consider their impact on the directors’ assertion on compliance with the Code and SIC requirements. Above all, the importance of understanding that the reporting of significant weakness is just one part of the equation—this must be accompanied by reporting on the steps since taken (or to be taken) to address these weaknesses. The focus on robust internal controls, comprehensive risk management and effective governance remains a critical requirement for State bodies.  The SIC is not just a compliance requirement; it also serves as a reflection of the organisation’s commitment to transparency, accountability and continuous improvement.  As State bodies navigate evolving challenges and expectations, adopting a standardised yet adaptable framework, combined with clear guidance, will strengthen overall SIC governance practice.    Dr Tom Ward is Senior Governance Specialist, Professional Development, with the Institute of Public Administration Níall Fitzgerald, FCA, is Head of Ethics and Governance at Chartered Accountants Ireland