The Institute, under the auspices of CCAB-I, made representations on behalf of members at last week’s meetings of Main TALC and TALC Collections. Amongst the issues discussed, Revenue provided updates on debt warehousing, share based remuneration and LPT and asked members to remind taxpayers to update their bank details on ROS if moving accounts from Ulster Bank or KBC.
Debt Warehousing Scheme – End of Period 2
In October, Revenue intends to contact taxpayers whose Period 2 ends on 31 December 2022 advising them of the end of that phase and asking them to provide a payment schedule. Those eligible for the April 2023 Period 2 extension will receive letters in February 2023.
Revenue reiterated that taxpayers must engage with Revenue before Period 2 ends to outline their plans to pay the warehoused debt. Should a Phased Payment Arrangement (PPA) be required it must be applied for through the normal online channels, with caseworker approval. It is also possible to pay off the debt early. Revenue advised that ROS has been amended so that VAT refunds may be offset against warehoused debt.
Revenue reminded the forum that it is vital that taxpayers availing of debt warehousing file all returns, even Nil returns, and pay current taxes as they fall due, otherwise the benefits of debt warehousing will be revoked. Debt warehousing arrangements have been revoked from over 24,000 taxpayers due to outstanding returns.
Debt Warehousing Scheme – Self-Review Period 1
Revenue advised that it intends to write to taxpayers in the coming weeks, offering them the opportunity to self-review their tax affairs for Period 1. Revenue will give taxpayers, by concession, time to quantify undisclosed tax liabilities and appropriate penalties from Period 1 and include them within warehoused debt. This window of opportunity is open until 31 January 2023.
Initially, Revenue will be writing to the 84,000 taxpayers currently availing of the debt warehousing scheme. A second tranche of letters will then issue to over 200,000 taxpayers, who either could have availed of debt warehousing but did not, or who availed of debt warehousing for a short period. The opportunity to make an unprompted qualifying disclosure of any previously undisclosed debt that would have been eligible for warehousing in Period 1 will be given to them on the same terms as taxpayers participating in the warehouse.
The compliance campaign will take place under Level 1 of the Compliance Framework. Beyond the closing date of 31 January 2023, further liabilities identified from Period 1 in relation to warehouse eligible taxes will result in a revocation of warehousing rights and interest and penalties apply as normal.
Share based remuneration schemes
Revenue reaffirmed its increased focus on employee share scheme compliance, noting that there are numerous inconsistencies in the data provided by employers. Revenue stressed the importance of employer returns and the data contained in these returns.
Revenue identified issues at employee level including a lack of awareness and education, in particular in relation to the different tax events a share award can lead to. While Revenue has encountered many innocent errors it is concerned it is not seeing CGT and dividend income where expected. As there is a high volume of cases in scope, Revenue wants to give taxpayers sufficient opportunity to amend matters. Revenue is considering a Level 1 non-filer campaign at the year end.
We will keep members updated via Chartered Accountants Tax News.
LPT
Revenue has informed us that 30,000 Form 11s are currently exposed to the LPT surcharge. To avoid multiple communications, Revenue recommends that taxpayers comply with LPT requirements prior to filing income tax or corporation tax returns. A customer service notification compliance campaign will commence this month with the intention to prompt taxpayers into action.
Update bank details on ROS
Revenue has asked us to remind readers to update their bank details for both online payments and repayments where they have changed banks as a result of Ulster Bank and KBC exiting the market. Revenue noted that there may be a need to update the details under more than one tax head and across several platforms.