Tax Relief for New Start-Up Companies

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Tax Relief for New Start-Up Companies

New start-up companies who set up and commence a qualifying trade on or before 31 December 2026 may be able to reduce their corporation tax bill for their first 5 years of trading.

The aim of the relief is to support businesses in the early stages of growth by reducing, and in some cases fully eliminating, corporation tax payable on the profits of the new trade and certain chargeable gains, helping to improve cash flow while the business is getting established.

The relief applies where the company’s total corporation tax payable for the period does not exceed €40,000. Marginal relief is also available where the total corporation tax payable is more than €40,000 but less than €60,000.

The relief available each year is linked to the total Employer’s Pay Related Social Insurance (PRSI) the company pays for its employees and directors. This includes Employer’s PRSI up to a maximum of €5,000 per employee and Class S PRSI up to a maximum of €1,000 per director.

Any unused relief arising in the first 5 years of trading, due to losses or insufficient profits, may be carried forward for use in subsequent years.

This relief is intended for genuine trading activities and does not apply to investment or passive income.

Qualifying Conditions

  1. The company must be incorporated in the State, the EU/EEA or in the United Kingdom on or after 14 October 2008.
  2. The company must set up and commence a “qualifying trade” in the period beginning on 1 January 2009 and ending on 31 December 2026. The following are not qualifying trades for the purpose of this relief:
    • A trade that was carried on previously by another person (this rules out sole traders incorporating their trade into a limited company).
    • An existing trade (this rules out forming a new company and acquiring a new trade).
    • An excepted trade (i.e. dealing in or developing land, exploration and extraction of petroleum or working minerals).
    • Service company activities that come within S. 441 TCA close company provisions.
    • A trade if carried on by an associated company of the new company would form part of the existing trade carried on by the associated company.
  3. The company does not exceed the specified levels of corporation tax due.

Example A:

A start-up company’s corporation tax for an accounting period is €20,000, referable entirely to income and gains from a qualifying trade. The total amount of qualifying Employer’s PRSI paid in the accounting period is €17,000.

The amount of relief available for the accounting period is €17,000, meaning the corporation tax referable to income and gains of the qualifying trade is reduced from €20,000 to €3,000.

Example B:

A start-up company’s corporation tax referable to income and gains from a qualifying trade for an accounting period is €20,000. The company also has corporation tax of €3,000 due on its investment income. The total amount of qualifying Employer’s PRSI paid in the accounting period is €25,000.

The amount of relief available for the accounting period is €20,000, meaning the corporation tax referable to income and gains of the qualifying trade is reduced to nil. The company must pay corporation tax of €3,000 on its investment income. The excess relief amount of €5,000 can be carried forward for use in future accounting periods following the five-year relevant period.

Example C:

The total corporation tax payable by a start-up company for an accounting period is €16,000. This refers entirely to income from a qualifying trade. The company has three employees and paid the following amounts of Employer’s PRSI in the accounting period:

Employee Details Employer’s PRSI paid €
Employee 1 2,000
Employee 2 3,000
Employee 3 6,000
Total PRSI 11,000

The amount of qualifying Employer’s PRSI is capped at €5,000 per employee. Therefore, the aggregate amount of qualifying Employer’s PRSI for the period is €10,000 (i.e. €2,000 plus €3,000 plus €5,000).

The relief available is €10,000, meaning the corporation tax of €16,000 referable to income of the qualifying trade is reduced to €6,000.

Conclusion

This relief can be particularly valuable for new businesses with employees, but careful planning at the start of the business is important to ensure the relief can be accessed and fully utilised.

Should you require any assistance in this area, please contact us.

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15 Promotions Mark a New Chapter of Growth at Crowleys DFK

15 Promotions Mark a New Chapter of Growth at Crowleys DFK

Crowleys DFK is delighted to announce the promotion of 15 talented and dedicated colleagues across the firm. These promotions reflect the continued growth of our business, the ambition of our people, and our commitment to developing future leaders at every level.

This latest round includes a new Director, three Senior Managers, seven Managers, and four Assistant Managers, one of our largest promotion groups in recent years. Each individual has demonstrated exceptional professionalism, leadership, and a commitment to delivering outstanding service to our clients.

These achievements also highlight the expanding opportunities being created through our recent partnership with the Shaw Gibbs Group, strengthening our capabilities and supporting clear, sustained pathways for career progression. Our shared focus on Learning & Development continues to play a central role in empowering our people to grow and excel.

Crowleys DFK Managing Partner James O’Connor commented:

“We are incredibly proud of our colleagues who have achieved promotion. Their dedication, hard work, and leadership embody the values that drive our firm forward. As we continue to grow and deepen our partnership with the Shaw Gibbs Group, we remain committed to supporting every stage of our people’s development. Congratulations to all on these well‑deserved achievements, and we look forward to their continued contributions to our success.”

Congratulations to Ciara, Conor, Aoife, Amy, Marie, Malcolm, Thomas, Salem, Gavin, Conor, Brian, Ciara, Paul, Múireann and Kristine. We are delighted to recognise the significant impact each of them makes across our firm and for our clients every day.

Meet Our Newly Promoted Colleagues

Meet Our Newly Promoted Colleagues

If you are interested in developing your career with Crowleys DFK, please visit our Careers page.

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Updates to OECD Model Tax Convention for Permanent Establishment for Remote Working

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Updates to OECD Model Tax Convention for Permanent Establishment for Remote Working

Although cross-border teleworking already existed before the Covid-19 pandemic, its scope and impact grew considerably during and after the pandemic, and this upward trend is still ongoing.

On 19 November 2025, the OECD released significant updates to the Commentary on the Model Tax Convention (the “Commentary 2025”).

A key focus of these updates is the treatment of Permanent Establishments (PEs) in situations where employees work remotely from a home office or another location that has no formal connection to their employer. The revised Commentary provides important clarifications to Article 5 of the Convention, particularly in the context of modern, flexible working arrangements.

The Commentary on Article 5 (Permanent Establishment): Use of a Home Office

The 2025 Update introduces a new analytical framework for assessing when remote or home-working arrangements may create a Permanent Establishment (PE). The OECD’s updated guidance includes a time-based indicator and a commercial‑reason test to determine whether an employee’s home or other location abroad constitutes a fixed place of business.

  1. Time-based indicator: The guidance establishes that a home or relevant place will not be considered a fixed place of business if the individual works there for less than 50 per cent of their working time, assessed over any 12-month period.If an individual meets the time indicator i.e. works from home for 50% or more of their working time, wider facts and circumstances will be considered, with emphasis on whether the business has a commercial reason for activities in the employee’s home jurisdiction.
  1. Commercial reason test: A commercial reason will be present where the individual directly engages with customers, suppliers, associated enterprises or other persons on behalf of the enterprise; and that engagement is facilitated by the individual being located in that State.However, the mere presence of customers or suppliers does not automatically establish a commercial reason.  If there is no genuine commercial reason for working from that location, it generally will not be considered a place of business for the company, unless other specific facts suggest otherwise.

The updated Commentary contains five illustrative examples reflecting common fact patterns:

  • Example A – Luca, an IT consultant based in Ireland, spends three months working from a rented apartment in Lisbon. Because the accommodation is used only on a temporary, short‑term basis and lacks continuity, it is not regarded as a fixed place of business for his employer.
  • Example B – Emma, who normally works in Dublin, relocates temporarily to Barcelona and carries out around 30% of her duties from her home there. While her Spanish home is a “fixed” location, she works there for less than half of her time. As a result, it is not considered a place of business and does not create a PE for the company.
  • Example C – Jonas moves to Munich and performs approximately 80% of his work from his home office. He also routinely meets clients located in Germany. The home is “fixed” and, because there is a commercial reason (serving local clients), it is considered a place of business and a permanent establishment for the company.
  • Example D – Sofia is based in Porto and spends about 60% of her time working from her home office. However, she provides services to clients across several countries and only occasionally visits a local client in Portugal. Despite the high level of home‑working, there is no commercial reason for her to be in Portugal, so her home office does not constitute a place of business or give rise to a PE.
  • Example E – Aisha works almost entirely from her home in Singapore, delivering virtual support and services to customers located across Asia‑Pacific time zones. Her presence enables the company to serve those markets more effectively. In this case, the home office is fixed and commercially driven, and therefore is likely to be considered a place of business that results in a PE.

Our View

With remote working becoming an increasingly common request, whether from an employee’s home or another overseas location, businesses have faced ongoing uncertainty around potential tax implications and how best to structure their remote work policies.

Overall, the updated guidance offers more clarity and flexibility for organisations managing cross‑border remote working arrangements.  Employers are advised to monitor the frequency with which employees conduct work outside the jurisdiction of their employment contracts, carefully assess remote work policies for potential permanent establishment risks, and maintain comprehensive records of all related processes and procedures.

If you need assistance reviewing your remote working policy, or have any queries in relation to the updated commentary, please feel free to contact us.

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Revenue clarifies its position on RCT for Mixed Contracts

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Revenue clarifies its position on RCT for Mixed Contracts

Revenue previously updated its Relevant Contracts Tax Manual in June 2025 to include a detailed section on contracts for the acquisition of property, especially where both construction services and land supply are involved.

The guidance confirmed that where a contract provides for both construction services and the supply of land, only the construction services are subject to RCT. If there is a single consideration for both, the principal must apportion the amount applicable to construction services. This marks a change from previous Revenue guidance, which stated that if any part of a contract was for relevant operations (construction, meat processing or forestry), all payments under that contract were liable for RCT.

In a welcome development, Revenue has now updated its Relevant Contracts Tax Manual in February 2026 in relation to mixed contracts. Mixed contracts include elements within the scope of RCT and elements that fall outside it, for example:

  • A contract to provide design‑and‑build services to a principal; and
  • A contract for the supply and installation of systems in a building or structure.

Revenue’s most recent guidance now confirms that where a single contract price covers both RCT‑relevant and non‑RCT elements, the principal is required to apportion the consideration. RCT should then be applied only to the portion of the contract relating to construction operations.

What Does This Mean for Mixed Contracts?

  • The legislation does not provide for RCT to apply to services outside the definition of construction, meat processing, or forestry operations.
  • For mixed contracts, the contract value must be apportioned between construction services (the relevant contract) and other elements (e.g., sale of land, design services, materials).
  • Activities that are integral to an overall construction project (e.g. site clearance, excavation, tunnelling and boring, laying of foundations, erection of scaffolding, site restoration, landscaping and the provision of roadways and other access works) remain within the scope of RCT.

What Does This Mean for Repair & Maintenance Contracts?

The new guidance maintains Revenue’s position that RCT applies to contracts for repair work and to contracts for repair and maintenance work.

Takeaway for Contracts with Mixed Elements:

If you’re entering into contracts that combine construction, meat processing, or forestry operations with other services or sales, ensure you can clearly apportion the contract value. RCT will only apply to the part of the contract that relates to relevant operations.

Should you require any assistance in this area, please contact us.

 

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Taxation of Dividends from Irish Companies

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Taxation of Dividends from Irish CompaniesIn accordance with the Companies Act 2014, an Irish company may only pay a dividend out of distributable reserves. A company cannot lawfully distribute capital or pre‑acquisition profits.

All dividends must be paid proportionally to the amount of shares held, subject to any special rights attached to specific share classes.

Tax Treatment of Dividends from Irish Companies

When an Irish company pays a dividend, it is obliged to deduct Dividend Withholding Tax (DWT) at 25% from dividend payments before distributing them to shareholders. This applies to both resident and non‑resident shareholders, unless an exemption applies.

The company paying the dividend must file details of the distribution and remit withheld tax within 14 days of the end of the month in which dividends are paid.

Exemptions from Dividend Withholding Tax

Under the EU Parent/Subsidiary Directive, no DWT is deducted from any distributions made by an Irish resident subsidiary to its parent in another EU Member State. In addition, exemptions from DWT apply in the following circumstances:

  • Payment to Irish resident companies.
  • Payment is to excluded Irish resident persons – certain pension funds, charities and other approved entities.
  • Payments to qualifying non-resident individuals.
  • Payments to qualifying non-resident companies.
  • Payments to qualifying non-resident persons (not being an individual or company).

For the above categories, a completed exemption form must be retained by the company paying the dividend. The exemption forms for corporates and other non-individuals are self-certified, however, in respect of non-resident individuals, their exemption must be certified by the tax authorities in which they are tax resident. The paying company should ensure they renew any exemption certificates every six years.

In the absence of a valid exemption certificate DWT must be applied.

Personal Taxation of Dividend Income

Irish resident individuals are liable to tax on the dividends received from Irish Companies. The dividend income is added to an individual’s total income for the year and liable to tax, USC and PRSI. A credit is granted for the DWT paid.

While the focus is on dividends from Irish companies, it is useful to contrast how foreign dividends are taxed for Irish residents for example:

  • UK dividends: Taxed in Ireland on the net amount received, with no credit for UK withholding.
  • US dividends: Withholding is typically 30% but reduced to 15% with a W‑8BEN. Ireland taxes the gross, with credit for US withholding.
  • Other foreign dividends: Again, taxed in Ireland but depending on where a tax treaty exists between Ireland and the paying country and the conditions thereof, the rate of withholding tax may be reduced or provide relief in respect of the foreign tax withheld.
  • Foreign dividends received by an Irish tax resident individual may suffer Irish Encashment Tax. A credit is available an individual’s Irish tax liability for the Encashment Tax.

Corporate Tax Treatment of Dividends

Irish dividends received by Irish resident companies are considered Franked Investment Income and are exempt from Corporation Tax.

Additionally, from January 1, 2025, a participation exemption applies to qualifying foreign dividends where the shareholder holds at least 5% of the company for 12 months, making such dividends exempt from Irish corporation tax.

If foreign dividends do not meet the criteria for the participation exemption, they are typically subject to Irish Corporation Tax at the standard rate of 25%. However, a reduced rate of 12.5% applies if the dividend is paid from trading profits, provided that, during the relevant period from which the profits are derived:

  • The company distributing the dividend is resident in an EU Member State or a country with which Ireland has a Double Taxation Agreement (DTA); or
  • The main class of shares of the company paying the dividend (or its parent holding at least 75% ownership) has been substantially and regularly traded on a recognised stock exchange in Ireland, the EU, or a DTA country.

The 12.5% regime for foreign dividends has been extended to dividends paid out of trading profits by:

  • A company that is resident in a non-treaty country where the company is owned directly or indirectly by a public company; and
  • A company that is resident in a territory that has ratified the Convention on Mutual Administrative Assistance in Tax Matters.

Where foreign tax on some dividends exceeds the Irish tax payable, the excess credit may be offset against Irish tax arising on other foreign dividends where the foreign tax is less than the Irish tax.

Unused credits can be carried forward indefinitely, but must be reduced by the Irish tax rate, and offset in the same way in subsequent accounting periods.

Excess foreign tax credits arising on dividends must be split into two between credits arising on 12.5% dividends and credits arising on 25% dividends, as excess credits from 12.5% dividends cannot be offset against Irish tax on 25% dividends.

If you require any assistance in this area, please contact us.

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Crowleys DFK Joins Shaw Gibbs Group with New Investment

Crowleys DFK Joins Shaw Gibbs Group with New Investment

Pictured L-R: James O’Connor (Managing Partner, Crowleys DFK), Peter O’Connell (CEO, Shaw Gibbs Group) and Edward Murphy (Partner & Head of Tax Services, Crowleys DFK)

Crowleys DFK is excited to announce a strategic partnership with UK-based Shaw Gibbs, joining the Shaw Gibbs Group, as well as an agreement for further strategic investment from its investor, Apiary Capital.  This partnership and investment marks a significant milestone in the firm’s journey and will accelerate growth in three core areas: Learning & Development, Technology, and Succession Planning.

This partnership builds on Shaw Gibbs’ track record of merging with successful accountancy and business advisory practices and builds on Apiary Capital’s proven track record of investing in transformative companies.  Shaw Gibbs is a top 35 leading accountancy and business advisory firm that secured investment from Apiary in November 2022.  Apiary is a UK-based private equity firm renowned for supporting owner-managed businesses across the business, financial, technology, education, and healthcare services sectors.

Since the original investment from Apiary Capital, Shaw Gibbs has demonstrated its success in merging with 11 other accountancy and advisory businesses and invested funding and expertise in infrastructure, digital innovation, and operational excellence.  Shaw Gibbs has grown organically and through acquisition from its base in Oxford to 18 offices across central and southern England with 56 partners and over 600 people serving over 20,000 SMEs, corporates and private clients. This affiliation brings exciting opportunities for collaboration, shared expertise, and long-term strategic alignment.  The partnership with Crowleys DFK is the first business outside of the UK that Shaw Gibbs has welcomed into its group.

Importantly, both Crowleys DFK and Shaw Gibbs are proud members of DFK International, a global alliance of accounting firms providing audit, tax and advisory services, working closely together across over 430 offices in over 90 countries.

“We’re proud to be working with Shaw Gibbs, whose partnering philosophy, culture and  strategy align closely with our own vision,” said Managing Partner, James O’Connor. “This is a significant moment for our firm, and we’re excited about what lies ahead.”

“While this partnership represents a significant step forward, our day-to-day operations remain unchanged. Our firm name, brand, leadership team, and client relationships will continue as they are. This investment is about reinforcing our foundation—not altering it.”

“This partnership is more than financial, it’s a shared commitment to sustainable growth, innovation, and impact. With our strengthened connection to the Shaw Gibbs Group and the financial support from its Investor, we are well-positioned to build on our success and shape the next chapter of our firm’s evolution.”

Peter O’Connell, CEO of Shaw Gibbs said:

“We have worked with James and the team at Crowleys DFK for a number of years sharing knowledge and business strategies as well as working together on client matters. The partnership allows for an investment in the Crowleys DFK business and team to achieve further growth, development and investment in the Irish market.”

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Revenue Announce Change to Territorial Scope of VAT Groups

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Revenue has published eBrief No. 216/25 confirming significant changes to its interpretation of VAT grouping rules in Ireland.

What’s Changed?

  • VAT grouping is now limited to Irish establishments only – a head office or branch located in Ireland.
  • Non-Irish head offices or branches of VAT group members are no longer considered part of the Irish VAT group.
  • This new guidance applies immediately to VAT groups established from the date of publication (19 November 2025).
  • Existing VAT groups have a transitional period until 31 December 2026 to comply.

Previous Position

Revenue previously treated the entire legal entity (including overseas branches) as part of the Irish VAT group. This interpretation has now changed.

Impact

From 1 January 2027, transactions between Irish VAT group members and their overseas branches will generally fall within the scope of Irish VAT.

Next Steps

Revenue advises:
“Those existing VAT Groups impacted by this change can contact their Revenue District to agree suitable transitional arrangements to ensure compliance with this guidance.”

If you have any queries, please contact us.

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Crowleys DFK Announces Latest Promotions

Crowleys DFK Announces Latest PromotionsAs Crowleys DFK closes its 50th year in business — a milestone reflecting enduring strength and growth— the firm is delighted to announce the promotion of five committed individuals to key management positions within the firm.

These promotions highlight Crowleys DFK’s unwavering commitment to nurturing talent and recognising excellence. Each individual has demonstrated outstanding dedication, leadership, and a passion for delivering exceptional client service, contributing significantly to the firm’s ongoing success and collaborative culture.

Managing Partner James O’Connor commented:

“Crowleys DFK is incredibly proud to recognise the hard work, commitment, and leadership shown by Jocelyn, Carol, Domenic, Kevin, and Ana. As the firm celebrates 50 years in business, these promotions highlight the strength of the team and the focus on developing talent from within. The firm looks forward with confidence, knowing our newly promoted colleagues will help lead us into the future.”

Looking ahead, Crowleys DFK is confident that these new leaders will play a pivotal role in shaping the next chapter of the firm.

Congratulations to Jocelyn, Carol, Domenic, Kevin, and Ana on this well-deserved recognition!

Meet Our Newly Promoted Team Members

If you are interested in developing your career with Crowleys DFK, please visit our Careers page.

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Tax Treatment of Meals Provided to Employees

Tax Treatment of Meals Provided to Employees

Revenue published new guidance on the provision of staff meals which has come into effect from 1 October 2025 (Tax and Duty Manual Part Part 05-01-01o).

The guidance reiterates Revenue’s position in relation to the existing exemption for meals provided in canteens open to all staff and also provides welcome clarity on the tax treatment of staff meals provided outside a designated ‘canteen’ setting.

The term “meals” in this context is interpreted broadly to include a variety of food and beverages such as hot meals, sandwiches, snacks, fruit, biscuits, tea, coffee, water, juice, and soft drinks. Alcoholic beverages are explicitly excluded.

1. Meals provided on the Employer’s Premises

Meals brought onto and consumed on the employer’s premises will not be considered a taxable benefit-in-kind (BIK), provided the following conditions are met:

  1. The meals are made available to all employees; and
  2. Consumption takes place on the employer’s premises.

Example A: A hotel has 10 employees and there is no designated staff canteen. All employees are provided with a meal and a soft drink in the hotel restaurant each day they are working. As the meals are provided to all staff, and are served and consumed on the employer’s premises, the cost incurred by the employer will not be treated as a taxable BIK.

Example B: An employer with 30 office-based staff provides fruit baskets and non-alcoholic beverages in the board room for 10 senior staff members. There is no operational requirement for providing the refreshments. As the refreshments are not available to all staff, a taxable BIK arises for the 10 staff that avail of the benefit.

If meals are not available to all staff, or not consumed on the premises, the cost is a taxable BIK.

2. Working Lunches

Where employers provide meals to only a specific cohort of employees, such as “working lunches” or “working dinners”, to facilitate operational requirements / business needs, Revenue has confirmed that these will not be treated as a taxable BIK, where the following conditions are satisfied:

  1. A specific operational requirement must exist (e.g., meetings, overtime),
  2. The meals are consumed on the employers’ premises,
  3. The cost per employee must not exceed the 5-hour Civil Service subsistence rate (currently €19.25).

Example A: In November 2025, in order to complete a stock take, 10 of the 55 staff of a supermarket work overtime until 11:30pm. The employer orders in pizza at 8pm for the 10 employees so the employees do not need to leave the store. The total cost of the pizzas is €165. As the cost of the pizzas for each person (€16.50) does not exceed the 5-hour rate, there is an operational requirement and the pizzas are consumed on the employer’s premises, this will not be treated as a taxable BIK.

Example B: A manufacturing plant that usually ceases production at 8pm each evening schedules a non-routine night shift for 12 employees to meet production targets, providing dinners costing a total of €300. The cost incurred per employee is €25. As this amount exceeds the 5-hour rate, a BIK charge to tax arises on the full €25 per employee.

Where, tea, coffee, biscuits, etc. are available to all staff on the employer’s premises, this will not impact the daily limit per employee.

3. Meal Vouchers

The long-standing 19c deduction per voucher is abolished. From 1 October 2025, the full value of any employer-provided meal vouchers is treated as a taxable Benefit-in-Kind (BIK) and must be included in the employee’s notional pay for Income Tax, PRSI, and USC purposes.

Summary

Scenario Taxable BIK Key Conditions
Staff Canteen No ·       Open to all staff
Meals for all staff on company premises No ·       Available to all staff

·       Consumed on premises
Working lunches (operational need) No ·       Operational Need

·       Consumed on premises

·       ≤ €19.25 per person
Meals for select staff (no operational need) Yes ·       Not available to all staff, OR

·       No operational requirement
Meal vouchers (from 1 Oct 2025) Yes ·       Full face value taxable

·       No 19 cent deduction

To avail of the tax-free treatment, employers must maintain adequate records including the date the refreshments were provided, the total cost of the refreshments and the number of employees who availed of the refreshments.

Revenue may conduct spot checks, and where the daily cost limit is exceeded, the entire cost becomes taxable as a BIK and must be included in payroll for Income Tax, PRSI, and USC purposes.

Should you require any assistance on the  Tax Treatment of Staff Meals, please contact us.

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Revenue Issues Guidance on Karshan Disclosure Opportunity for Employers

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Revenue Issues Guidance on Karshan Disclosure Opportunity for Employers

In October 2023, the Supreme Court delivered an important judgment on the key factors to be considered to determine whether a worker is an employee or self-employed for income tax purposes. The Court decided that the question should be resolved using a five-step process.

Revenue then published guidance in May 2024 explaining the new five-step decision-making framework. It encouraged all businesses to review the nature of any contractor-type arrangements and consider any implications the Kharshan judgement may have for them.

Revenue have recently announced Karshan Disclosure Opportunity Guidance, an opportunity for employers to correct any payroll tax issues in respect of 2024 and 2025, arising from bona fide misclassification of employees as self-employed workers without penalty or interest. The deadline for submission of disclosures to avail of these favourable settlement terms is 30 January 2026.

Businesses who engage contractors should self-review all arrangements with contractors in light of the new five-step framework to see if a disclosure is required before the 30 January 2026 deadline.

If you require our assistance with this, please contact us.

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