by Ariful | Sep 1, 2026 | EU VAT Updates
TITLE: 1 September 2026 Tax Update: DPN Review, Property Data Matching, and Business CGT Changes
Tuesday, 1 September 2026 brings several important Australia tax updates for directors, property owners, employees and growing businesses. The Australian Taxation Office (ATO) is facing an official review of its Director Penalty Notice process, while data matching has identified thousands of unreported investment property sales. Businesses should also prepare for upcoming CGT concession changes, new deduction rules and continuing crypto tax consultations.
Protect your company from a Director Penalty Notice
The Tax Ombudsman has launched a review into how the ATO administers Director Penalty Notices (DPNs).
The ATO issued more than 84,000 DPNs during 2024–25 to directors of approximately 64,000 companies. This represents a 136% increase compared with the previous financial year.
A DPN can make a company director personally liable for unpaid:
- PAYG withholding.
- Goods and Services Tax (GST).
- Superannuation Guarantee Charge (SGC).
The review will examine whether the ATO’s case selection, communication and recovery processes are fair and proportionate. It will also consider the position of directors affected by:
- Serious illness.
- Coercive or abusive directorships.
- Financial abuse.
- Resignation timing issues.
- A lack of awareness about company tax liabilities.
The review does not suspend ATO enforcement. Directors must continue to respond to DPNs within the applicable deadlines.
Under the ATO director penalty regime, the 21-day period generally begins when the notice is posted or left at the address registered with ASIC. It does not necessarily begin when you personally read the notice.
Complete this DPN compliance checklist
If you are a director of an Australian company in Sydney, Melbourne, Brisbane, Perth, Adelaide or elsewhere in Australia:
-
Review your ATO account regularly.
This helps you identify unpaid GST, PAYG withholding or superannuation before enforcement escalates.
-
Lodge BAS and payroll reports on time.
Timely lodgement may prevent certain liabilities from becoming subject to lockdown rules.
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Reconcile your payroll and superannuation records.
This reduces the risk of hidden SGC liabilities and incorrect employee reporting.
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Keep ASIC records current.
A DPN may be posted to the registered address even if you no longer operate from that location.
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Act immediately if a DPN arrives.
The 21-day period is strict. Delaying action can restrict the options available to you.
We can help you keep bookkeeping, GST, BAS, payroll and tax records organised so potential liabilities are identified earlier.
Review every investment property sale before 31 October
The ATO has identified approximately 6,000 investment property sales made between 1 July 2020 and 30 June 2025 where owners may not have declared the resulting capital gain or loss.
The estimated tax liability is approximately $66 million.
The ATO’s data matching combines information from sources including:
- Banks and lenders.
- State and territory revenue offices.
- Land titles offices.
- Property managers.
- Settlement records.
- Conveyancing data.
The reported campaign focuses on investment properties. Principal place of residence sales are excluded from the identified campaign. However, special main residence rules can apply where a property was used as both a home and an investment.
The ATO generally expects a capital gain or loss to be reported in the income year when the contract of sale is signed, rather than the settlement date.
Affected taxpayers have reportedly been given until 31 October 2026 to lodge or dispute the ATO’s position. Taxpayers who do not engage may face a default assessment. Penalties of up to 75% of the tax shortfall may apply in serious cases, together with interest.
Check your property CGT position now
Use this checklist if you sold an investment property in Australia:
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Find the contract date.
This confirms the relevant tax year.
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Locate the purchase contract and settlement statement.
These documents support your cost base calculation.
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Gather stamp duty, legal and agent costs.
Eligible acquisition and disposal costs may reduce the taxable gain.
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Review renovation and improvement invoices.
Capital improvements may affect the cost base.
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Check periods of private and rental use.
This is important if the property was previously your main residence.
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Review lodged tax returns.
Confirm that the sale and any capital gain or loss were reported correctly.
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Respond to ATO correspondence before the deadline.
Early action gives you a better opportunity to correct errors and explain the position.
Read the ATO’s guidance on property and capital gains tax before lodging an amendment or response.
Prepare for the $10 million small business CGT threshold
From 1 July 2027, the aggregated turnover threshold for the 50% active asset CGT reduction will increase from $2 million to $10 million.
This change is significant for Australian businesses that are growing beyond the traditional small business threshold.
However, the reform does not increase the threshold for every small business CGT concession. The following concessions remain subject to the existing $2 million turnover threshold or the $6 million maximum net asset value test:
- The 15-year exemption.
- The retirement exemption.
- Small business rollover relief.
The $10 million threshold applies specifically to the 50% active asset reduction. You will still need to satisfy the other eligibility conditions, including the active asset requirements and relevant ownership tests.
Treasury confirms the reform in its small business CGT explainer. Start reviewing your ownership structure, connected entities and aggregated turnover now. Accurate records will make it easier to assess eligibility when the new rules commence.
Track the $1,000 standard deduction consultation
The ATO is consulting on draft Law Companion Ruling LCR 2026/D5, which explains the new standard deduction for work-related expenses.
From the 2026–27 income year, eligible Australian tax residents who earn assessable labour income may claim a standard deduction of up to A$1,000 for eligible work-related expenses.
The measure is now law, but the draft ruling provides practical interpretation. It is important to remember:
- The deduction does not apply to the 2025–26 tax return.
- The maximum is g
by Ariful | Aug 31, 2026 | Banking
TITLE: SME Banking & Fintech Review: FX, AI Assistants, and Instant Payments
This week’s SME Banking & Fintech Review covers four developments shaping international business finance in September 2026:
- Faster, more transparent FX through Stripe.
- Multi-currency banking from HSBC UAE.
- Agentic AI for business banking through Starling.
- Instant euro payments and Verification of Payee across Europe.
The common theme is clear. Banking is becoming more integrated with payments, accounting data, fraud controls and compliance workflows. For growing ecommerce brands, digital businesses and SMEs, the right financial setup can save time and improve reporting accuracy.
The key trend: banking is becoming operational infrastructure
SME banking is no longer limited to receiving money and making payments. Modern fintech platforms now help you:
- Hold and convert multiple currencies.
- Automate transfers and cash allocation.
- Detect suspicious invoices.
- Connect transaction data with accounting systems.
- Process payments instantly across borders.
This creates opportunities, but it also increases the importance of accurate bookkeeping. Every wallet, payment processor and currency conversion creates accounting data that must be reconciled correctly.
For a business comparing a multi-currency business account or looking for an ecommerce accountant UK companies can rely on, integration matters as much as headline fees.
1. Stripe expands instant FX and multi-currency settlement
Stripe announced new currency capabilities on 17 August 2026. The goal is to help global businesses reduce unnecessary conversions and manage FX within the same platform used to accept payments.
Stripe’s FX announcement introduces instant currency conversion between 15 currencies. Businesses can use the Stripe Dashboard, API or mobile tools to convert funds when needed.
Stripe says the service provides:
- Real-time rates.
- Transparent pricing.
- No hidden markups embedded in the exchange rate.
- No weekend surcharges.
- Conversion access throughout the day.
This can help you avoid the “double FX” problem. For example, a business may receive USD, convert it into GBP, and later convert GBP back into USD to pay an overseas supplier. Holding and converting funds closer to the point of use can reduce unnecessary movement.
Stripe also reports that the number of businesses using multicurrency settlement grew by 35% between 2024 and 2025. Companies growing by 40% annually were more than twice as likely to use multicurrency settlement as businesses growing by 10% or less.
By the end of 2026, Stripe expects multicurrency settlement to reach 37 markets, including Australia, Hong Kong and Singapore. Depending on location, businesses will be able to settle funds in up to 18 currencies.
The examples are relevant for international sellers:
- French mobile gaming company Voodoo earns more than half of its revenue from US customers. It can now settle US payment earnings in euros, helping reduce repeated FX costs.
- Canva is also identified as a business using Stripe’s currency tools for high-volume international payments and operating expenses.
Stripe plans to add automated conversions and expanded API workflows by the end of 2026. This could allow businesses to set rules for payroll, supplier payments or month-end currency management.
What you should do: Review where your business converts currencies. Compare the cost of converting at checkout, at settlement and when paying expenses. Then ensure each movement is recorded correctly in your bookkeeping system.
2. HSBC UAE launches an “immediately international” account
On 25 August 2026, HSBC UAE launched an upgraded Premier Global Money Account. HSBC describes it as the UAE’s first “immediately international” account.
The account combines multi-currency features under:
- One account.
- One IBAN.
- One linked Visa debit card.
Customers can hold, spend, transfer and receive money in more than 20 currencies. HSBC’s product information lists up to 21 holding currencies, including AED, USD, EUR, GBP, CAD and AUD.
For international business owners and executives, this may simplify personal cross-border money management. The account can receive supported foreign currencies through SWIFT without automatic conversion, helping users retain funds in the currency received.
HSBC also states that supported Global Money transfers have no HSBC transfer fees. However, the fee details require careful attention.
Certain standard bank-transfer routes, including payments outside HSBC in a non-local currency, may attract an AED 75 plus VAT charge. Unsupported-currency card transactions can also incur processing fees. Correspondent or receiving banks may apply separate charges.
This is an important reminder for every business owner: “fee-free” usually applies only to specific routes, currencies and transaction types.
The Premier Global Money Account is a personal banking product, not a replacement for a properly structured business account. You should keep company funds separate from personal funds. This protects your records and makes bookkeeping, expense verification and year-end reporting easier.
What you should do: Before selecting any international account, check:
- Which currencies you can hold.
- Which currencies you can receive without conversion.
- Whether the IBAN is suitable for your customers or suppliers.
- Which transfer routes carry fees.
- How statements and transaction data can be exported.
3. Starling Assistant brings agentic AI to business banking
On 24 August 2026, Starling launched Starling Assistant for business customers.
The free in-app assistant is described as agentic because it can execute certain banking tasks rather than only answer questions.
Tax Ring-Fencing helps protect cash for VAT
A business owner can ask the assistant to put aside a percentage of recent earnings for VAT. The tool calculates the amount from account history and transfers it into a dedicated Space.
This is useful because VAT money can easily be mistaken for available working capital. Ring-fencing creates a practical buffer before the return and payment deadline.
However, an automated percentage is only a starting point. Your correct VAT liability depends on taxable sales, input VAT, corrections, imports, credit notes and the accounting period. The Space does not replace a VAT calculation or VAT return.
Invoice Fraud and Scam Defence adds a second check
Starling Assistant can review invoice concerns and flag warning signs. If supplier payment details change, for example, it may recommend contacting the supplier directly using known contact details.
Starling cites UK Finance figures showing that invoice fraud cost businesses more than £41 million in 2025. A second check can prevent an expensive payment mistake.
MTD Navigator provides guided information
The MTD Navigator is intended to help certain self-employed users understand whether they may need to follow Making Tax Digital for Income Tax rules. It can direct users to HMRC information and sign-up resources.
For UK Limited Companies, remember that this is not a substitute for corporation tax compliance. The assistant provides guidance, but your final tax position should always be reviewed by a qualified accountant or tax adviser before submission.
by Ariful | Aug 31, 2026 | E-Commerce
TITLE: Key VAT and Compliance Tasks for Ecommerce Sellers: Week of 31 August 2026
The week of 31 August 2026 brings important compliance tasks for Amazon and Shopify sellers. Review your Pan-EU FBA listings, update your VAT reconciliation process, and prepare your records while HMRC considers further marketplace changes.
Protect Pan-EU FBA eligibility before 3 September
Amazon has confirmed that every Pan-European FBA product must have an active offer on the Netherlands marketplace from 3 September 2026. This applies to both new and existing Pan-EU FBA products.
A similar requirement will apply to Belgium from 26 February 2027.
This is an important operational change for UK Limited Companies selling across Europe. If a product does not have the required active offer, it may lose eligibility for Pan-EU FBA benefits.
Complete this Amazon checklist
- Review every ASIN enrolled in Pan-EU FBA.
- Confirm that the product has an active offer on Amazon.nl.
- Check that the listing uses the correct SKU and product information.
- Resolve suppressed, inactive, or incomplete listings.
- Record the date each offer was checked.
- Schedule a second review before the Belgium requirement begins.
Amazon’s official Pan-European FBA guidance confirms that the Netherlands and Belgium listing requirements do not automatically mean that you must store stock in those countries.
An active offer alone does not automatically create a Dutch or Belgian VAT registration obligation when your stock is held elsewhere. However, your VAT position still depends on your establishment, fulfilment model, inventory locations, customer type, and use of the Union One Stop Shop.
Do not confuse listing activity with inventory storage. Storing goods in another country can create local VAT registration and reporting obligations. Review Amazon’s inventory movement reports so you know where your goods are physically held.
For UK sellers using Pan-EU FBA, this distinction is central to accurate Amazon Pan-European VAT compliance.
Reconcile Amazon’s shipment-level VAT calculations
Amazon’s VAT Calculation Service moved to shipment-level VAT calculation on 1 June 2026.
Previously, Amazon calculated and rounded VAT separately for each unit. The new method groups items by tax rate and calculates VAT on the total invoice amount before rounding.
This can create small differences between Amazon’s VAT reports and your accounting system.
For example:
- Six units priced at £1.99 each.
- VAT rate of 10%.
- Unit-level calculation: £1.99 × 10% = £0.199, rounded to £0.20 per unit.
- Total under the old method: £1.20.
- Shipment-level calculation: £11.94 × 10% = £1.194, rounded to £1.19.
The difference is only one pence. However, repeated across thousands of orders, these discrepancies can affect VAT control accounts, invoice matching, and month-end reporting.
Update your reconciliation process
Use Amazon’s actual reports as the source for the VAT amount charged on each shipment. Do not rely only on a per-unit calculation in your bookkeeping software.
Your process should:
- Group items by shipment and VAT rate.
- Calculate VAT on the aggregated amount.
- Round the total at shipment level.
- Compare the result with Amazon’s VAT Calculation Report.
- Record any rounding difference in a controlled rounding account.
- Check refunds and credit notes against the original shipment calculation.
The Amazon VAT Calculation Service methodology explains that sellers remain responsible for ensuring their VAT settings, product tax codes, VAT registration numbers, and ship-from locations are accurate.
This is particularly important for sellers using both Amazon FBA and seller-fulfilled orders. The actual ship-from location can affect the VAT treatment.
A reliable Amazon FBA accounting UK process should reconcile:
- Product sales.
- Customer VAT.
- Amazon-collected VAT.
- Seller-accounted VAT.
- FBA fulfilment fees.
- Storage and removal fees.
- Refunds and reimbursements.
- Currency conversion differences.
- Inventory movements between fulfilment centres.
Prepare for possible UK marketplace VAT changes
HMRC’s consultation on extending online marketplace VAT liability closed on 18 August 2026. The government response is still pending.
The proposal considers extending marketplace VAT liability to certain sales made by UK-based businesses through online marketplaces. The consultation also considered measures such as a minimum platform threshold and VAT rate relief for businesses below the VAT registration threshold.
There is no confirmed implementation date or new rule for UK sellers at the time of writing. Current VAT responsibilities continue to apply.
You should still prepare your records now. This will save time if new reporting or marketplace data requirements are introduced.
Organise the data HMRC may need
Maintain a clear record of:
- Marketplace sales by platform.
- Direct website sales.
- Total taxable turnover.
- Sales by legal entity.
- UK and overseas customer locations.
- VAT-registered and non-VAT-registered customers.
- Returns, refunds, and discounts.
- Marketplace fees and deductions.
- Inventory held in the UK and overseas.
- VAT collected by marketplaces.
- VAT accounted for by your company.
The UK VAT registration threshold remains more than £90,000 of taxable turnover in a rolling 12-month period. The optional deregistration limit remains less than £88,000.
Use HMRC’s VAT threshold guidance and monitor your turnover every week. Do not wait until your year-end accounts are prepared. A rolling calculation gives you earlier notice of a potential registration obligation.
Strengthen Shopify and Amazon bookkeeping before growth accelerates
Growth can hide accounting problems. A business may show strong sales while losing margin through VAT leakage, marketplace fees, refunds, currency movements, and slow inventory turnover.
Your ecommerce bookkeeping UK process should connect sales data with cash, inventory, VAT, and profitability. Recording only bank deposits is not enough because marketplace payouts are usually net of fees, refunds, reserves, and adjustments.
For Shopify sellers, Shopify accounting UK should separately identify:
- Gross online sales.
- Shopify Payments settlements.
- PayPal and other payment providers.
- Transaction and subscription fees.
- Refunds and chargebacks.
- VAT collected at checkout.
- Shipping income and costs.
- Marketing and fulfilment expenses.
For Amazon sellers, the same principle applies. Your records should be built from transaction-level reports rather than payout totals.
This is where an ecommerce accountant UK can provide ongoing operational support. At Sterlinx Global, clients provide their business and platform data while we co
by Ariful | Aug 31, 2026 | UAE Updates
TITLE: Australian Tax Compliance Update: 31 August 2026
Monday 31 August 2026 brings several important Australian tax compliance developments. The most urgent is today’s Pillar Two filing deadline for eligible multinational groups.
You should also review trust distributions after the Bendel decision, monitor proposed foreign resident capital gains tax reforms, and check historical R&D claims before the ATO publishes its next transparency report.
Lodge Pillar Two returns by today’s deadline
The ATO’s first Pillar Two lodgment deadline applies today to groups with a fiscal year ending 28 February 2025.
For these groups, the Combined Global and Domestic Minimum Tax Return (CGDMTR) and the GloBE Information Return (GIR) are due by 31 August 2026. This is the first applicable fiscal year, so the deadline falls 18 months after year-end.
The ATO’s Pillar Two lodgment guidance explains the filing requirements.
Complete this checklist now
- Confirm whether your group is within the Australian Pillar Two rules.
- Prepare and lodge the CGDMTR through the approved ATO channel.
- Lodge the GIR in Australia where Australian filing is required.
- If the GIR is filed centrally in another jurisdiction, complete the Australian foreign lodgment notification.
- Check that any GIR XML file passes ATO validation.
- Keep evidence of calculations, data sources, approvals and submission receipts.
The CGDMTR brings together the relevant domestic minimum tax, income inclusion rule or undertaxed profits rule reporting, and foreign lodgment notification obligations.
Central filing does not remove the Australian compliance requirement. Even where the GIR is filed overseas by an ultimate parent entity or designated filing entity, the Australian constituent entity may still need to lodge its CGDMTR and identify the foreign filing location.
Do not assume that an administrative deferral changes the statutory deadline. The ATO cannot extend the statutory deadline for the GIR or foreign lodgment notification. PCG 2025/4 sets out the ATO’s compliance approach to central filing and transitional issues, but you should still treat today as the required filing date.
Recheck trust cash movements after Bendel
The High Court’s decision in Commissioner of Taxation v Bendel [2026] HCA 18 has changed the treatment of unpaid present entitlements, or UPEs.
A bare UPE owed by a trust to a private company is not automatically a Division 7A loan. The ATO’s Decision Impact Statement accepts the High Court’s reasoning. The ATO has also confirmed that Taxation Determination TD 2022/11 will be withdrawn.
This is an important change. However, it does not make every trust-company arrangement safe.
Follow the money, not just the accounting entry
For each corporate beneficiary UPE, trace what happened to the underlying funds.
Ask:
- Did the company receive and retain the funds?
- Did the trust later pay or lend money to a shareholder or associate?
- Were trust assets used privately by a shareholder or related party?
- Is there a formal loan agreement separate from the UPE?
- Do the distribution records match the actual economic benefit?
Subdivision EA can still apply where trust funds connected with a corporate beneficiary’s entitlement are used to make payments, loans or debt forgiveness in favour of a shareholder or associate.
Section 100A also remains relevant. If trust income is appointed to one beneficiary while another person receives the practical benefit under a reimbursement arrangement, the trustee may face tax at the top marginal rate.
This means your post-Bendel review should be evidence-based. Reconcile trust resolutions, bank statements, loan accounts, beneficiary entitlements and private use of funds. The same process applies whether your business operates in Sydney, Melbourne, Brisbane, Perth, Adelaide or elsewhere in Australia.
Treasury is also consulting on potential changes that could bring UPEs within Division 7A. The current High Court position applies today, but future legislation may change the compliance outcome.
Track the foreign resident CGT Bill, but do not treat it as law
The Treasury Laws Amendment (Strengthening Accountability for Tax Adviser Misconduct and Other Measures) Bill 2026 passed the House of Representatives in August and is progressing through Parliament.
It is not yet law.
The proposed foreign resident CGT reforms would strengthen the rules for interests connected with Australian land and natural resources. Key measures include:
- A broader definition of “real property”.
- A 365-day look-back period for the principal asset test.
- Wider coverage of indirect Australian real property interests.
- Additional notification requirements for certain transactions worth $50 million or more.
- Changes to the foreign resident capital gains withholding framework.
- A targeted 50% CGT discount for eligible renewable energy assets.
The $50 million figure is not a general FRCGW threshold. It relates to proposed additional notification and declaration obligations for certain high-value share or membership-interest transactions.
The Bill’s renewable energy measure has also advanced in the House, with the proposed concession extended towards 30 June 2040. The final outcome depends on Senate passage, Royal Assent and the commencement provisions.
Until the Bill becomes law, apply the current rules. For transactions involving Australian land, land-rich entities, renewable infrastructure or overseas vendors, document:
- The residency of each party.
- Whether the asset is taxable Australian property.
- Whether an indirect Australian real property interest exists.
- Whether a clearance certificate or declaration is required.
- Whether foreign resident capital gains withholding applies.
- The contract and settlement dates.
This preparation will reduce settlement delays when the legislation takes effect.
Prepare for enacted 2026 tax reforms
The Treasury Laws Amendment (Tax Reform No. 1) Act 2026 received Royal Assent on 26 June 2026.
Several measures are scheduled to apply from 1 July 2027.
The Act includes changes to the capital gains tax system. For eligible Australian resident individuals and trusts, the 50% CGT discount is replaced by cost-base indexation for relevant gains. A 30% minimum tax on certain capital gains also applies under the new framework.
The Act also restricts negative gearing for established residential dwellings acquired after the relevant 12 May 2026 cut-off. Losses from affected properties are quarantined and generally carried forward against later residential property income or r
by Ariful | Aug 31, 2026 | US Updates
TITLE: FIRE to IRIS Transition: Final Deadlines Every International Seller Must Know
The IRS is retiring the FIRE system in November 2026. If you file US information returns, you must prepare for the move to IRIS before the 2027 filing season.
This change matters to UK sellers in London, Manchester and Birmingham, EU ecommerce businesses, foreign-owned US LLCs and international companies selling into the US through Amazon FBA, Shopify and other marketplaces.
The IRS announced the transition in News Release IR-2026-99, published on 24 August 2026.
Act before these three FIRE deadlines
The transition includes three important dates. Missing the final date could prevent you from filing through FIRE.
1. Test your information returns by 1 November 2026
1 November 2026 is the final day to file test information returns through the FIRE Trading Partner Test System.
Use this deadline to:
- Test your filing software.
- Check your file format.
- Validate payer and recipient data.
- Identify rejected records.
- Confirm that your third-party filer can transmit successfully.
Testing early gives you time to correct technical errors before the production system closes. Do not wait until the final filing deadline to discover that your data file is invalid.
2. Update your FIRE application by 9 November 2026
9 November 2026 is the last day to make changes to Information Returns Applications for Transmitter Control Codes, commonly called TCCs.
Review your existing FIRE application now. Check:
- Responsible officials.
- Authorised contacts.
- Business details.
- Filing responsibilities.
- Third-party transmitter arrangements.
- The information returns your business expects to submit.
After this date, changes to your FIRE application will no longer be available in the same way. Keeping your records accurate helps prevent access and authorisation problems during the transition.
3. File through FIRE by 19 November 2026
19 November 2026 at 3 p.m. Eastern Time is the final deadline for filing information returns through FIRE.
That is 8 p.m. UK time on 19 November 2026.
This is the most important deadline for international sellers. If you have outstanding FIRE filings, corrections or other submissions, plan to complete them well before the final afternoon.
After the November maintenance window, FIRE will no longer accept information returns. From 1 January 2027, IRIS will be the sole IRS electronic filing system for information returns, including current-year, prior-year and correction filings.
Move from FIRE to IRIS before the 2027 filing season
IRIS, or the Information Returns Intake System, is the IRS replacement for FIRE. The IRS has provided two filing channels.
Use the free IRIS Taxpayer Portal for smaller filing volumes
The IRIS Taxpayer Portal is a free, web-based filing system.
You can use it to:
- Enter information manually.
- Upload data using a CSV file.
- File up to 100 returns per filing.
- Download payee copies.
- Maintain records of completed submissions.
The portal may suit a smaller business filing a limited number of 1099 forms. It is also useful if you do not have a compatible third-party filing system.
Prepare your data carefully. A CSV upload does not remove your responsibility to provide accurate taxpayer identification numbers, payment information and recipient details.
Use IRIS Application to Application for higher volumes
IRIS Application to Application, or A2A, is designed for high-volume filers using third-party software or their own systems.
This channel may be more suitable if you:
- File hundreds or thousands of information returns.
- Use accounting, payroll or compliance software.
- Need an automated system-to-system process.
- Already rely on a third-party transmitter.
- Want to reduce manual data entry.
Ask your software provider whether it supports IRIS A2A. Do this early because testing, authorisation and data mapping may take time.
Understand the IRIS TCC requirement
Your existing FIRE TCC will not automatically work with IRIS.
You must apply for an IRIS TCC through the IRS. FIRE TCCs and IRIS TCCs are system-specific. They are not interchangeable.
This is a key operational point for any business that currently uses FIRE for 1099 filing or other US information returns. Applying for the correct IRIS TCC early will reduce the risk of a last-minute filing failure.
Keep evidence of:
- Your IRIS application.
- TCC approval.
- User permissions.
- Software authorisation.
- Test submissions.
- Rejected and corrected records.
These records support a clear compliance trail if you need to investigate a filing issue later.
Check the foreign filer process
International sellers need to understand which IRS process applies to them.
A non-US filer without an SSN or ITIN may need to use the Foreign Filer TCC Registration system for the applicable electronic filing process. The registration process includes:
- Signing in through Login.gov or ID.me.
- Creating or accessing a Foreign Filer account.
- Obtaining a Foreign Filer ID.
- Obtaining a TCC GIIN.
- Enrolling in IDES where required.
- Allowing approximately three to six weeks for the process.
The Foreign Filer ID is not the same as a TCC. The TCC GIIN is also a specific identifier used for the relevant registration and enrolment process.
Do not assume that a Foreign Filer TCC, FIRE TCC, IRIS TCC and IDES credentials can be used interchangeably. They cannot. Confirm which channel applies to your filing obligation before submitting an application.
If your foreign business has an authorised user with a US SSN or ITIN, the IRS may direct you to apply for an IRIS TCC through the standard IRIS process instead. Review the latest IRS foreign filer guidance and IRIS TCC instructions before proceeding.
See how the change affects international sellers
Example 1: A UK Amazon seller filing US forms
A UK Limited Company based in London sells products to US customers through Amazon FBA. Its US reporting obligations may include 1099 forms or Form 1042-S, depending on the payments, recipients and structure involved.
The business should:
- Review which US information returns it files.
- Confirm whether it currently uses FIRE or a third-party transmitter.
- Test its files before 1 November.
- Review its FIRE application before 9 November.
- Submit any required FIRE returns before 19 November at 3 p.m. ET.
- Apply for the correct IRIS TCC or follow the applicable foreign filer process.
- Confirm that Amazon, its software provider or its filing agent has a 2027 IRIS workflow.
The same approach applies to sellers operating from Manchester, Birmingham or elsewhere in the UK.
Example 2: A foreign-owned US LLC using a third-party filer
A foreign-owned US LLC receives marketplace income and uses an external provider to prepare and transmit its information returns. The LLC may not interact with FIRE directly, but it remains responsible for the accuracy and timely submission of its filings.
The LLC should:
- Verify that its third-party filer is registered for IRIS and has a valid IRIS TCC.
- Ask whether the filer will use the IRIS Taxpayer Portal or A2A for the 2027 season.
- Obtain confirmation in writing that test files have been accepted in the IRIS environment.
- Review the filer’s timeline for completing the transition before November 2026.
- Check that the LLC’s own records—such as recipient name, address and taxpayer identification number—are up to date.
- Plan for a possible gap in filing capacity if the third-party filer is slow to migrate.
This example also applies to foreign-owned LLCs that do not have direct IRS filing accounts and rely entirely on external compliance partners.
Example 3: An EU business with Form 1042-S obligations
An EU ecommerce business with US-source payments may need to file Form 1042-S to report income paid to foreign persons. If it currently uses FIRE for this purpose, the transition to IRIS requires a fresh look at its entire filing setup.
The business should:
- Determine whether it files as a foreign filer or through a US-based agent.
- Secure the correct Foreign Filer TCC or IRIS TCC well ahead of the transition date.
- Complete any IDES enrolment if required for its specific filing type.
- Test its 1042-S data files in the new system before the end of the test window.
- Allow the three to six weeks processing time for foreign filer registration.
- Coordinate with any withholding agents to ensure beneficiary data matches.
Missing the transition deadlines could delay 1042-S filings and create compliance exposure for the business.
Prepare your transition plan now
The FIRE to IRIS transition is not a routine software update. It is a system-wide change that affects how information returns are tested, transmitted and tracked.
Build your plan around these steps:
Audit your current filing method
Identify every form your business files through FIRE. This may include Forms 1099-NEC, 1099-MISC, 1099-K, 1042-S or others. Verify whether you file directly or through a third party.
Confirm your TCC status
Check whether your existing TCC is a FIRE TCC or an IRIS TCC. If you have not applied for an IRIS TCC, start the process immediately. If you are a foreign filer, confirm whether the Foreign Filer TCC Registration system applies to you.
Contact your software provider
Ask your software vendor or filing agent whether they support IRIS A2A. Confirm their testing schedule and request evidence of successful IRIS test transmissions.
Set internal milestones
Work backwards from 19 November 2026. Set internal deadlines for completing test files, updating applications and finalising submissions. Do not rely on the IRS deadlines as your only reference points.
Document everything
Keep copies of all applications, approvals, test submissions, error reports and correction records. This documentation will be useful if the IRS contacts you about a filing issue during the transition period.
Act before the November 2026 cut-off
The FIRE system is closing. The IRS will not extend the 19 November 2026 deadline for individual filers or business filers, regardless of jurisdiction.
International sellers and foreign-owned entities face additional complexity because of the Foreign Filer TCC Registration process and the three to six week processing time. Starting the application process in mid-2026 gives you a realistic buffer.
If you file US information returns of any type, your next step is clear: test early, update your applications before 9 November, and complete all FIRE submissions before 19 November at 3 p.m. Eastern Time. Then move your entire workflow to IRIS before the 2027 filing season begins.
