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Update from the recent meeting of the TALC Collections Sub-Committee

Mar 04, 2024

The Institute, under the auspices of the CCAB-I, made representations on behalf of members at last week’s meeting of the TALC Collections Sub-Committee. Among the issues discussed, Revenue provided an update on the Debt Warehousing Scheme and outlined local property tax and vacant home tax compliance projects it has commenced. Revenue also reminded the group that the 2023 Form 11 has been updated for taxpayers wishing to claim the Mortgage Interest Tax Credit and/or the Rent Tax Credit. Minutes will be available in due course. 

Debt Warehousing Scheme – 1 May 2024 deadline 

Readers are reminded that taxpayers that have neither paid warehoused debt in full nor commenced the application process for a phased payment arrangement (PPA) by 1 May 2024 will be required to repay the debt is full and will be subject to interest at 10 percent, backdated to when the debt arose. 

Revenue is urging taxpayers seeking a PPA to submit their payment proposal (via ROS) by 1 May 2024. Revenue will then work with the taxpayer to formulate a repayment plan. Once a PPA is approved, Revenue has stated that there is flexibility within the system to allow for the first payment to start after 1 May 2024. 

Revenue noted that letters will issue to taxpayers in the DWS in March. Due to GDPR issues, these letters will not be copied to agents.  

At end of January 2024 there was €1.7 billion debt warehoused by 57,000 taxpayers of which 30,000 owed less than €1,000 (most of whom owed less than €500). €1.4 billion is owed by 5,200 taxpayers, each owing in excess of €50,000. These taxpayers operate in the wholesale/retail, accommodation and food, construction and professional scientific sectors. 

Refunds interest totalling €500,000 are due to be made to 475 taxpayers that paid interest of 3 percent.  Taxpayers with PPAs in progress that include the 3 percent interest rate will receive a priority ROS Inbox Notification. They will be required follow certain steps in ROS to trigger the 0 percent interest rate and must ensure they complete the ‘sign and submit’ section to accept the updated payment schedule. 

Local Property Tax  

Taxpayers were required to have their 2024 local property tax (LPT) liability payment arrangement in place by 10 January 2024. Single annual direct debits will be collected on 21 March 2024. Properties that became suitable for use as a dwelling after 1 November 2022 and on or before 1 November 2023 become liable to LPT for the first time in 2024, based on the market value of the property at 1 November 2021. 

Revenue noted that some taxpayers who pay their LPT by deduction at source from pay or pension have failed to file an LPT return. Revenue advises that they file an LPT return as soon as possible in order to avoid issues at a later date. 

Revenue informed the group that compliance work is underway in 2024, focusing on property valuations project where there has been a decrease in valuation band in period 2 (2022-2025) from the original valuation band in period 1 (2013-2021).  

In addition, Revenue also intends to review properties where taxpayers have claimed uninhabitable status, which may also have a vacant homes tax (VHT) impact if subsequently deemed habitable. 

Vacant Homes Tax  

Revenue intends writing to persons that own 20 or more properties this week, asking them to declare whether the property is occupied or is vacant. Where vacant, and not already returned, a return and payment will be required to regularise their affairs. Revenue intends to undertake a similar communications campaign when it moves on to contact the middle cohort of property owners with 2 to 19 properties at a later date. 

Letters of No Objection for voluntary strike-off 

Revenue is aware of delays experienced by taxpayers in obtaining a Letter of No Objection for a voluntary strike-off. While 82 percent of cases were responded to within 30 days in quarter 4 2023, Revenue is endeavouring to reduce the timeframe for issuing such letters. Revenue advises practitioners to use the Exceptional Contact channel in urgent cases where delays arise. Revenue recommends that applicants engage with Revenue as soon as possible and supply all the mandatory information at the beginning of the process. More details are available on revenue.ie 

Form IT38 

The capital acquisitions tax (CAT) return Form IT38 for the period 1 September 2023 to 31 August 2024 was made available in Revenue’s Return Preparation Facility (RPF) on 26 February 2024. Form IT38 for earlier periods will become available from 26 March 2024 but, in the meantime, they can be prepared using the ROS Offline application. 

Employee Share Options 

As readers will be aware, from 1 January 2024 the taxation of a gain realised on the exercise, assignment or release of share options no longer falls under individual self-assessment. Instead, employers are responsible for collecting income tax, USC and PRSI from employees on share option gains and remitting those taxes to Revenue as part of the payroll process. Revenue has updated its website for these changes and additional text has been added to screens to alert anyone trying to submit relevant tax on share options (RTSO) for 2024.  

The self-assessment regime continues to apply to gains arising on or before 31 December 2023, as does the obligation to register for Relevant Tax on Share Options (RTSO). The 2023 Form 11 is available to any taxpayer wishing to submit their 2023 income tax return. Revenue’s advice to taxpayers that will no longer be chargeable persons for income tax purposes for 2024, is to de-register for income tax via ROS once their 2023 income tax return has been submitted. 

2023 Form 11 matters 

  • Revenue has been informed of issues with the pre-population of Department of Social Protection information in the 2023 Form 11 and is continuing to investigate the matter. We will keep readers informed via Tax News. 

  • The 2023 Form 11 has been updated for taxpayers wishing to claim the Mortgage Interest Tax Credit and/or the Rent Tax Credit. 

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