Latest Tax news

In Irish news, the Institute has given evidence to the Oireachtas on proposals to substantially alter the right to elect for a private hearing at the Tax Appeals Commission, and a delegation from the Institute attended the seventh meeting of the Department of Finance’s Business Tax Stakeholder Forum. In UK news, with the start of Financial Year 2026 and ahead of the 2026/27 tax year, we are launching a series of articles on various key changes. We are also seeking your views on an HMRC consultation on a proposal for new reporting requirements for close companies in respect of transactions with participators. In International news this week, the EU Council and Parliament have agreed on landmark reform of the EU customs framework. Ireland 1. Read about the evidence given by the Institute to the Joint Committee on Finance, Public Expenditure, Public Service Reform and Digitalisation, and Taoiseach outlining the importance of protecting taxpayer privacy. 2. Read the updates from the recent meeting of the Business Tax Stakeholder Forum which was attended by representatives from the Institute. UK 3. Read the first in our series of articles looking at various key changes due to commence at the start of the new Financial Year 2026 and the tax year 2026/27. 4. HMRC is consulting on two areas relevant to companies and we are particularly seeking your views on the proposal requiring close companies to report additional information on transactions with participators. International 5. The European Council and Parliament have agreed to a reform of the EU Customs Union including the establishment of a new single EU customs data hub. 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 Cross-border developments and trading corner here.  

Over the next few weeks in a series of articles we’ll be taking a look at the key changes to UK tax legislation which have come into operation due to commencement of the new Financial Year 2026 from earlier this week on 1 April 2026, or when the new tax year 2026/27 starts next week on 6 April 2026. Part 1 of this series focuses on Making Tax Digital (MTD) for Income Tax and measures affecting tax agents. MTD for Income Tax 6 April 2026 marks the go live mandatory start date of MTD for Income Tax. Mandation commences from this date for self-employed individuals and landlords with qualifying gross income (not profit) which exceeded £50,000 in the 2024/25 tax year. The mandation limit subsequently falls from 6 April 2027 to £30,000, and then to £20,000 from 6 April 2028. MTD requires those mandated to keep digital records and submit quarterly summaries of income and expenses to HMRC via compatible software. The first deadline for submitting MTD 2026/27 quarterly updates for quarter 1, which for most mandated taxpayers will run from 6 April 2026 to 5 July 2026, is 7 August 2027. Members can access the Institute’s MTD hub for support on this key change. Ahead of the start date, HMRC has published breakdowns by industrial sector and geographic region of the taxpayers expected to be within scope of MTD for Income Tax from April 2026. The data is based on information from 2023/24 Self-Assessment returns.  Last week the Government laid the final regulations in Parliament on the requirements and scope of MTD for Income Tax. The regulations were laid after further amendments based on feedback from stakeholders, including Chartered Accountants Ireland. Key aspects of the regulations include the phased introduction of MTD for Income Tax based on income, including those with qualifying income over £30,000 from April 2027 and those over £20,000 from April 2028, the requirement to keep digital records and submit quarterly updates, and annual returns through MTD-compatible software. The regulations also offer practical features, such as the option to align reporting to calendar quarters and targeted exemptions for those for whom digital use would not be reasonably practicable.  A new Tax Information and Impact note (TIIN) on the £20,000 to £30,000 mandation cohort that will be joining MTD for Income Tax from April 2028 has also been published to supplement the TIIN published in 2024 for those with qualifying income above £30,000. The TIIN sets out the Government’s view on the taxpayer impact of MTD for Income Tax, including the cost to transition to and operate new software to comply. According to HMRC, although this is broadly comparable to those with qualifying income in excess of £30,000, the new TIIN reflects a different demographic, and revised ‘assumptions’ that underpin the estimated software costs, agents’ costs, training, and familiarisation time and free software take-up.   Measures affecting the tax adviser market From 6 April 2026 HMRC will have a range of enhanced powers to sanction tax advisers, in addition to new powers to tackle promoters of tax avoidance arrangements. Broadly, for the latter, there will be a statutory ban on promoting tax planning arrangements with ‘no realistic prospect of success.’ Regulations also will prohibit the promotion of arrangements ‘likely to cause harm to participants.’ The sanctions under this legislation will be severe and include significant penalties, a strict liability criminal offence, and the ability of HMRC to suspend an agent’s registration. Legislation will also take effect from 6 April 2026 which will amend the tax agent ‘dishonest conduct’ rules introduced by Finance Act 2012. Essentially, dishonest conduct will be downgraded and the rules will apply to tax advisers who facilitate non-compliance by their client. The associated penalty framework will also be substantially enhanced and will also require HMRC to publish information about any adviser charged a penalty exceeding £7,500. From May 2026 new rules will also require those providing tax advice, including overseas advisers, to mandatorily register with HMRC. Readers may recall that the timetable for registration was published last month. By way of reminder, registration is expected to officially open online from 18 May 2026. Importantly, if an agent already has an agent services account (ASA), the agent does not need to register again. Instead, HMRC will subsequently contact the agent via its ASA when more information is required in order to check that the agent meets certain conditions. Agents who do not have an ASA and who meet the conditions to register will need to register for an ASA from 18 May 2026, unless one of the following applies: if the agent already has a Self-Assessment or Corporation Tax account, registration is required from 18 August 2026, and if the agent only provides third-party payroll services on behalf of clients and does not interact with HMRC in any other way, registration is required from 18 November 2026. Note that irrespective of the registration date which applies, a transition period of at least three months is available. The legislation implementing this is contained in Finance Act 2026. According to statements made by government ministers in the House of Commons, whilst the draft legislation moved through the Parliamentary process, the measures which will directly affect tax agents, including mandatory registration, are expected to be implemented in a reasonable and proportionate manner. Dan Tomlinson MP, Exchequer Secretary to the Treasury (XST) specifically addressed comments on the draft legislation to the House of Commons during its scrutiny of the Finance Bill in early February 2026 which acknowledged engagement on these issues by the Professional Bodies, which includes Chartered Accountants Ireland, and the important role that agents play in the tax system. At column 223 the XST said “I have been engaging in detail with stakeholders on the changes we are making, because it is important that legitimate and good tax advisers see that the Government have confidence in them and the work they are doing”. He went on to say that agent registration is “specifically about stopping harmful tax advisers who do not meet the basic minimum standards” and that it does “not give HMRC new powers to investigate whether applicants breach the standard for agents”. On HMRC’s powers to suspend an agent’s registration, the XST said at column 224 that HMRC will: “suspend a tax adviser only after due process, including offering opportunities to comply and a chance for the adviser to explain whether there is a good reason why they are unable to do so”, and “not use these powers for minor breaches”. At column 230 the XST further said that HMRC will “always work with a tax adviser who is genuinely trying to comply, will never suspend a tax adviser when doing so would be unreasonable or disproportionate, and will always consider the nature of any potential breach and how a suspension would impact the tax adviser and their clients”. On sanctionable conduct, at column 235 the XST said that “the powers will not affect advisers who act in good faith, or who take a credible view as to what the law requires of their clients, including where they use extra-statutory concessions or HMRC guidance to form that view”. Furthermore, the measures “do not affect advisers who make mistakes while trying, as the vast majority do, to do the right thing”. The XST’s comments were echoed by Lucy Rigby MP, Economic Secretary to the Treasury (EST), when speaking about the prohibition on promotion. The EST confirmed at  column 204 that the powers “are not intended to be directed against legitimate tax advisers who are operating to a high professional standard but, while acting in good faith, make genuine mistakes” and that ministers have “asked HMRC officials to work with stakeholders in developing published guidance to address the fine detail of exactly how the prohibition will work in practice”.

Last Thursday, a delegation from the Institute attended the seventh meeting of the Department of Finance’s Business Tax Stakeholder Forum (BTSF) at the Department of Finance’s offices on Upper Merrion Street. The Department provided updates to stakeholders on a range of business tax issues both domestically and internationally, as well as providing an update on the work ongoing around the Irish Presidency of the European Council later this year. On the domestic front, the Department explained its business tax priorities for 2026 and provided updates on various ongoing projects, such as Phase One of the reform of the taxation of interest in Ireland. One of the key priorities for 2026 on the business tax front is the Research & Development (R&D) tax credit and the recommendations arising from last year’s public consultation. Key to any changes which will be considered by the Department will be to identify the potential for additionality to the economic activity in Ireland. In terms of the now well publicised proposals for an Irish Savings and Investment Account, the Department acknowledged its consideration of the Swedish model in particular. As part of this work, a roadmap is expected to be published very shortly. We will have more details in due course once this is published. On the international front, the Department provided an update on the work to implement the Pillar Two Side-by-Side Package, and provided more detail into the work to commence on addressing the tax complexity faced by cross-border/hybrid workers on the island of Ireland. The work on Pillar Two is being addressed at a subgroup of the BTSF, which the Institute attends also. On the issues currently facing cross-border workers, we are due to meet the Department separately on this in the coming weeks and we will have a full update for readers at that point. Finally, on the EU Presidency, there is a substantial amount of work ongoing as the Government prepares to take up the role this summer. From a tax point of view, the Tax Omnibus Directive and the Directive on Administrative Cooperation (DAC) Recast Directive will be two files which the Government will be keen to progress during its term. From an overall perspective, the Government will be aiming to highlight the need for simplification in light of the impact of the current complexity on EU competitiveness. In closing, a short note on the BTSF for readers who may not be familiar with the forum. The BTSF was established as a forum between the Department of Finance and key stakeholders to discuss business tax policy. The meetings are chaired by senior Department officials and are attended by representatives from various trade and professional organisations, as well as other key governmental stakeholders. It has proven so far to be a very productive and engaging forum and we look forward to the continued success of the forum into the future.

Over the next few weeks, we’ll be taking a look at the key changes to UK tax legislation which take effect due to the commencement of either the new Financial Year 2026 from later this week on 1 April 2026 or the new tax year 2026/27 which starts next week on 6 April 2026. Part 1 of the series focuses on Making Tax Digital (MTD) for Income Tax and measures affecting tax agents. MTD for Income Tax 6 April 2026 marks the go live mandatory start date of MTD for Income Tax. Mandation commences from this date for self-employed individuals and landlords with qualifying gross income (not profit) which exceeded £50,000 in the 2024/25 tax year. The mandation limit subsequently falls from 6 April 2027 to £30,000, and then to £20,000 from 6 April 2028. MTD requires those mandated to keep digital records and submit quarterly summaries of income and expenses to HMRC via compatible software. The first deadline for submitting MTD 2026/27 quarterly updates for quarter 1, which for most mandated taxpayers will run from 6 April 2026 to 5 July 2026, is 7 August 2027. Members can access the Institute’s MTD hub for support on this key change. Ahead of the start date, HMRC has published breakdowns by industrial sector and geographic region of the taxpayers expected to be within scope of MTD for Income Tax from April 2026. The data is based on information from 2023/24 Self-Assessment returns.  Last week on 24 March 2026 the Government laid the final regulations in Parliament on the requirements and scope of MTD for Income Tax. The regulations were laid after further amendments based on feedback from stakeholders, including Chartered Accountants Ireland. Key aspects of the regulations include the phased introduction of MTD for Income Tax based on income, including those with qualifying income over £30,000 from April 2027 and those over £20,000 from April 2028, the requirement to keep digital records and submit quarterly updates, and annual returns through MTD-compatible software. The regulations also offer practical features, such as the option to align reporting to calendar quarters and targeted exemptions for those for whom digital use would not be reasonably practicable.  A new Tax Information and Impact note (TIIN) on the £20,000 to £30,000 mandation cohort that will be joining MTD for Income Tax from April 2028 has also been published to supplement the TIIN published in 2024 for those with qualifying income above £30,000. The TIIN sets out the Government’s view on the taxpayer impact of MTD for Income Tax, including the cost to transition to and operate new software to comply. According to HMRC, although this is broadly comparable to those with qualifying income in excess of £30,000, the new TIIN reflects a different demographic, and revised ‘assumptions’ that underpin the estimated software costs, agents’ costs, training, and familiarisation time and free software take-up.   Measures affecting the tax adviser market From 6 April 2026 HMRC will have a range of enhanced powers to sanction tax advisers, in addition to new powers to tackle promoters of tax avoidance arrangements. Broadly, for the latter, there will be a statutory ban on promoting tax planning arrangements with ‘no realistic prospect of success.’ Regulations also will prohibit the promotion of arrangements ‘likely to cause harm to participants.’ The sanctions under this legislation will be severe and include significant penalties, a strict liability criminal offence, and the ability of HMRC to suspend an agent’s registration. Legislation will also take effect from 6 April 2026 which will amend the tax agent ‘dishonest conduct’ rules introduced by Finance Act 2012. Essentially, dishonest conduct will be downgraded and the rules will apply to tax advisers who facilitate non-compliance by their client. The associated penalty framework will also be substantially enhanced and will also require HMRC to publish information about any adviser charged a penalty exceeding £7,500. From May 2026 new rules will also require those providing tax advice, including overseas advisers, to mandatorily register with HMRC. Readers may recall that the timetable for registration was published last month. By way of reminder, registration is expected to officially open online from 18 May 2026. Importantly, if an agent already has an agent services account (ASA), the agent does not need to register again. Instead, HMRC will subsequently contact the agent via its ASA when more information is required in order to check that the agent meets certain conditions. Agents who do not have an ASA and who meet the conditions to register will need to register for an ASA from 18 May 2026, unless one of the following applies: if the agent already has a Self-Assessment or Corporation Tax account, registration is required from 18 August 2026, and if the agent only provides third-party payroll services on behalf of clients and does not interact with HMRC in any other way, registration is required from 18 November 2026. Note that irrespective of the registration date which applies, a transition period of at least three months is available. The legislation implementing this is contained in Finance Act 2026. According to statements made by government ministers in the House of Commons, whilst the draft legislation moved through the Parliamentary process, the measures which will directly affect tax agents, including mandatory registration, are expected to be implemented in a reasonable and proportionate manner. Dan Tomlinson MP, Exchequer Secretary to the Treasury (XST) specifically addressed comments on the draft legislation to the House of Commons during its scrutiny of the Finance Bill in early February 2026 which acknowledged engagement on these issues by the Professional Bodies, which includes Chartered Accountants Ireland, and the important role that agents play in the tax system. At column 223 the XST said “I have been engaging in detail with stakeholders on the changes we are making, because it is important that legitimate and good tax advisers see that the Government have confidence in them and the work they are doing”. He went on to say that agent registration is “specifically about stopping harmful tax advisers who do not meet the basic minimum standards” and that it does “not give HMRC new powers to investigate whether applicants breach the standard for agents”. On HMRC’s powers to suspend an agent’s registration, the XST said at column 224 that HMRC will: “suspend a tax adviser only after due process, including offering opportunities to comply and a chance for the adviser to explain whether there is a good reason why they are unable to do so”, and “not use these powers for minor breaches”. At column 230 the XST further said that HMRC will “always work with a tax adviser who is genuinely trying to comply, will never suspend a tax adviser when doing so would be unreasonable or disproportionate, and will always consider the nature of any potential breach and how a suspension would impact the tax adviser and their clients”. On sanctionable conduct, at column 235 the XST said that “the powers will not affect advisers who act in good faith, or who take a credible view as to what the law requires of their clients, including where they use extra-statutory concessions or HMRC guidance to form that view”. Furthermore, the measures “do not affect advisers who make mistakes while trying, as the vast majority do, to do the right thing”. The XST’s comments were echoed by Lucy Rigby MP, Economic Secretary to the Treasury (EST), when speaking about the prohibition on promotion. The EST confirmed at  column 204 that the powers “are not intended to be directed against legitimate tax advisers who are operating to a high professional standard but, while acting in good faith, make genuine mistakes” and that ministers have “asked HMRC officials to work with stakeholders in developing published guidance to address the fine detail of exactly how the prohibition will work in practice”.

In this week’s detailed miscellaneous updates which you can read more about below, HMRC has sent a message on multi-factor authentication for tax advisers. In other news this week: HMRC has published the advisory fuel rates applying from 1 March 2026 for employees using a company car. We issue a reminder that from 1 April 2026, companies will be required to use commercial software to file company tax returns because HMRC and Companies House free software will no longer be available, The latest HMRC Stakeholder Digest and HMRC Agent Update 141 are available, HMRC has responded to the Adjudicator’s 2024/25 annual report, HM Treasury has announced a review of approved mileage allowance rates which have been unchanged since 2011, and With the price of chocolate skyrocketing whilst the size of Easter eggs are shrinking, HMRC has issued a Press Release on saving Easter childcare egg-spenses with Tax-Free Childcare. Multi-factor authentication for tax advisers HMRC has asked us to share the below message on changes to the agent’s sign-in journey. “HMRC Multi-Factor Authentication (MFA) – Change to theagent signin journey  HMRC are working closely with tax advisors and professional bodies to introduce Multi-Factor Authentication (MFA) to strengthen security on agent accounts. MFA will provide greater protection as agents sign in to HMRC’s services, helping to keep accounts and client data secure.   From Tuesday 7 April, to raise awareness of the upcoming introduction of MFA, agents will see a new page when signing in to their HMRC account on GOV.UK, linking to further guidance in the Tax Agent’s Handbook.  A small group of agent volunteers are currently participating in a period of MFA test and learn, with testing then due to expand in April. HMRC will be contacting agents who they recognise would benefit from early adoption of the additional security MFA offers. This may be agents who have previously contacted HMRC due to account suspension or to raise security concerns.   Members using automated processes or third-party software for their sign-in journey should check whether any software updates are needed and allow time for those adjustments. These changes only apply to web sign in on GOV.UK and will not affect services such as PAYE or Making Tax Digital for VAT. We urge agents to prepare and depending on their circumstances, identify the best approach for them to manage MFA’s introduction.  To give agents time to prepare, HMRC will confirm the MFA go-live date for the wider agent community as early as possible, currently scheduled for delivery by the end of June 2026, but subject to successful testing.”  

In this week’s cross-border trading corner, we bring you the latest guidance updates and publications. The most recent Trader Support Service bulletin is also available as is the latest Brexit and Beyond newsletter from the Northern Ireland Assembly EU Affairs team. The minutes and slides from the most recent meeting of the HMRC Stakeholder Forum, the Northern Ireland Joint Customs consultative Committee (which the Institute is represented on) are available together with ICS2 groupage HMRC guidance. Miscellaneous guidance updates and publications This week’s miscellaneous guidance updates and publications are as follows: Appendix 2 C21e: Data Element 1/11: Additional Procedure Codes, Additional Information (AI) Statement Codes for Data Element 2/2 of the Customs Declaration Service (CDS), CDS Declaration Completion Instructions for Imports, Previous document codes for Data Element 2/1 of the Customs Declaration Service, Known error workarounds for the Customs Declaration Service (CDS), Tax types for Data Element 4/3 of the Customs Declaration Service, Data Element 2/3: Documents and Other Reference Codes (Union) of the Customs Declaration Service (CDS), Maritime ports and wharves location codes for Data Element 5/23 of the Customs Declaration Service, National additional codes to declare with Data Element 6/17 of the Customs Declaration Service, UK Trade Tariff: duty suspensions and autonomous tariff quotas, Declaration Unique Consignment References, Entry in the Declarant's Records, Simplified Declaration Process, Simplified Customs Declaration Process, Get customs data for import and export declarations, Report a problem using the Customs Declaration Service, Procedures Codes and Additional Procedures Codes, Supplementary Declarations, Introduction, and Internal temporary storage facilities (ITSFs) codes for Data Element 5/23 of the Customs Declaration Service.

The European Commission has welcomed the agreement between the European Parliament and the Council to a reform of the EU Customs Union. The reform will establish a new single EU customs data hub which will digitalise and simplify procedures while tightening controls on non-compliant, dangerous or unsafe goods. Overall, the new system should allow for more robust controls without an excessive burden for authorities and traders.

Revenue has published a further warning of fraudulent emails, SMS (text messages) and phone calls seeking personal information from taxpayers. Revenue has updated its website to highlight recent fraudulent emails claiming that taxpayers are ‘due an audit’ and directing them to click a link to schedule the audit by a specified date. Examples of fraudulent emails and text messages are included in the communication. Taxpayers who have provided Revenue account details in response to an email, SMS or phone call are advised to reset their password immediately. Taxpayers are advised to contact their bank or credit card provider if they have provided bank or card details.

Revenue has updated its guide on how to protect your business from becoming involved in VAT fraud providing examples of relevant due‑diligence actions which can be undertaken when establishing a trading relationship with a supplier or customer.

The Tax and Duty manuals on  Revenue Information Powers and the Schedule of Revenue Powers have recently been updated to provide additional clarifications and to outline Revenue’s approach in exercising the relevant legislative powers. The guidance on Information Powers outlines that Revenue will notify a taxpayer in writing where a notice has been issued to a third party under section 902 TCA 1997 or to a financial institution under section 906A TCA 1997. The guidance on the schedule of Revenue powers now includes a reference to section 109A VAT Consolidation Act 2010 which empowers Revenue to require a taxable person who is not established in the EU to appoint an EU‑established tax representative. That representative will be responsible for the payment of any VAT arising from the supplies made by the taxable person within the State.

Revenue has updated its guidance on the operation and administration of the Pillar Two rules. The revised material provides additional detail and clarification on the application of the rules, offering further insight into how they are to be interpreted and implemented in practice. The relevant sections of the guidance on the operation of Pillar Two which have been updated are as follows: Section 5.1, to update guidance in respect of ultimate parent entities. Section 6.10, to update guidance in respect of section 111N - Calculation and allocation of UTPR top-up tax amount, as it relates to the allocation of UTPR among domestic constituent entities. Section 7.2, to update guidance in respect of intra-group financing arrangements and use of losses carried forward. Section 8.5 (section 111X – Total deferred tax adjustment amount) and section 12.1 (section 111AW – Tax treatment of deferred tax assets, deferred tax liabilities and transferred assets upon transition), as it relates to the utilisation of loss deferred tax assets, Section 9.6, to update guidance in respect of section 111AH - Minority owned constituent entities, as it relates to an orphan entity that is a constituent entity, Section 9.7 (section 111AI - Qualified domestic top-up tax safe harbour), Section 9.8 (section 111AJ - Transitional CbCR safe harbour) and section 12.1 (section 111AW – Tax treatment of deferred tax assets, deferred tax liabilities and transferred assets upon transition), as it relates to the treatment of certain deferred tax assets (DTA’s) arising from tax benefits provided by General Government, Section 13.3, to update guidance in respect of section 111AAC - Chargeable entities, as it relates to the reallocation of any QDTT calculated for a securitisation entity that is a minority owned constituent entity, and Section 13.4, to update guidance in respect of Section 111AAD - Determining top-up tax amounts of qualifying entity, as it relates to the application of the local accounting standard in calculating domestic top-up tax, in certain circumstances, notwithstanding that the fiscal year end does not align with that of the ultimate parent entity. The changes to the guidance on the administration of Pillar Two rules include: Updates with respect to the requirements of the Directive on Administrative Cooperation and the OECD Pillar Two Multilateral Competent Authority Agreement (MCAA), An update to reflect that the secondary collection mechanism for UTPR and QDTT liabilities do not apply to a securitisation entity in certain circumstances, and Updates with respect to the taxpayer obligation to keep records, the provision of related penalties for non-compliance, and Revenue’s power to inspect records. Several other minor amendments have been reflected throughout both documents.

Revenue has published updated guidance on the participation exemption for certain foreign distributions to reflect amendments contained in Finance Act 2025. Information on distributions‑in‑specie and how the tax deductibility of a distribution impacts the exemption claim are also included in the guidance. In general, for the purposes of the exemption, a relevant distribution does not include a distribution, or part of a distribution, that has been, or may be, deducted for tax purposes in any territory outside the State under the law of that territory. The guidance confirms that, from 1 January 2026, a distribution will not be excluded from being a relevant distribution solely because it is deductible for the purposes of a tax comparable to the close company surcharge in section 440 TCA 1997. Section three of the guidance, which outlines the conditions the foreign dividend-paying company must meet to qualify as a relevant subsidiary, has been updated to include the following information: Relevant distributions made on or after 1 January 2026 by a company resident in a non-EEA or non-tax treaty territory are in scope of the exemption if foreign withholding tax at a nominal rate greater than zero per cent is paid on the full amount of the distribution and not refunded. The definitions of “relevant period” and “reference period” are reduced from five years to three years, reducing the period in which a company must be resident in a relevant territory, or have not had certain excluded merger and acquisition activity, prior to making a distribution. In cases where the domestic law of a relevant territory does not determine a company’s residence, the residence position will be determined under the terms of the relevant territory’s tax treaty with Ireland. A company resident in a territory with which Ireland has a newly signed tax treaty is eligible to qualify as a relevant subsidiary from the date of signature of that tax treaty. In the case of a relevant distribution made on or after 1 January 2025, a distributing company is permitted, during the reference period, to have acquired a business or business assets consisting of shares, or to have moved residence from Ireland, or to have had merger and acquisition activity involving an Irish resident company.