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Update from the September 2023 meeting of TALC Collections subcommittee

Sep 11, 2023

The Institute, under the auspices of the CCAB-I, made representations on behalf of members at last week’s meeting of the TALC Collections subcommittee. Among the issues discussed, Revenue provided updates on the implementation of the Enhanced Reporting Requirements for employers, the Debt Warehousing Scheme and the non-resident landlord withholding tax. Revenue also informed the group that interest charges on the late payment of tax, suspended since March 2020, is to recommence this month. 

Enhanced Reporting Requirements for Employers 

Revenue intends to hold information webinars commencing 14 September 2023 on the new enhanced reporting requirements for employers for agents and employers. Invitations to attend the webinars will be delivered to the employer’s ROS inbox and an email notification is also to be provided. 

We will continue to keep members updated via Chartered Accountants Tax News. 

Debt Warehousing Scheme 

At the end of July 2023, the total debt warehoused was €1.9 billion consisting of over 60,000 businesses, 42 percent of which owe less than €500 each, with 66 percent owing less than €5,000 each. Just under 6,000 businesses owe a combined €1.6 billion, each owing in excess of €50,000. Revenue initiated a telephone outreach campaign in July, commencing with 600 businesses that each owe in excess of €500,000.  

The Debt Warehousing Scheme is currently in Period 3, running from 1 January 2023 to 1 May 2024, with interest accruing at 3 percent per annum on the unpaid debt. The 3 percent interest charge will be incorporated into the phased payment arrangement (PPA) for its duration. Where there is no PPA, the interest will be charged retrospectively. 

Taxpayers have until 1 May 2024 to agree a PPA with Revenue and are reminded that they can make interim payments during this period, and also request for the offset of any refunds owing against the balance of tax warehoused. To date there have been 2,200 agreed PPAs from the Debt Warehouse Scheme valued €100 million.  

Revenue is encouraging taxpayers to engage now in the PPA process as there is much flexibility in terms of payment terms, amounts and downpayments. In addition, payment breaks can be arranged once the PPA has been commenced. A nominal downpayment amount of 0.1 percent of tax and interest can be input using the online application system to commence the process of engagement and negotiation with the caseworker.  

Arrangements will be subject to review of supporting documentation contained in the Form ePPA1. For amounts exceeding €50,000 supporting bank statements are required to be uploaded, other documents such as cashflow statements and management accounts will also be required where the debt exceeds €100,000.  

Revenue has prepared a number of ‘How to” videos in relation to the PPA process which are now available on the Revenue website (link to videos). The topics covered include: 

  • PPA Application 

  • Defer your Next Payment 

  • Apply for a Payment Break 

  • Consolidation 

  • Change Bank Details 

  • Change Payment Date 

  • Pay in Full 

Revenue would encourage taxpayers to view these videos in advance of applying for a PPA to assist taxpayers to become familiar with the PPA online facility and understand the range of flexible payment options that are available to suit their individual circumstances.  

Non-Resident Landlords  

Following the introduction of the new non-resident landlord withholding tax (NLWT) system from 1 July 2023 over 4,300 rental notifications have been made in respect of 2,300 properties by over 1,000 filers in respect of €10 million rental receipts with €2 million withholding tax paid. These figures exclude HAP (circa 1,800 properties).  

There will be a further Tax and Duty Manual update in the coming weeks with improved functionality to allow amendments to rental notifications (RNs). Revenue confirmed that there has been an issue with setting up repeat RNs and this is the be fixed in the coming weeks. 

Section 216D TCA 1997 micro-generation of electricity

Section 216 D TCA 1997 provides for an exemption of up to €200 from income tax, USC and PRSI for certain profits arising to a qualifying individual who generates energy from renewable, sustainable or alternative energy sources for their own consumption and applies from 1 January 2022.  

Revenue advise that such income is assessable under Schedule D Case IV net of the exemption of €200. It should be included in Panel G Other Irish Income on the ROS Form 11 or included as non PAYE income ‘fees and commissions’ if filing a Form 12 where relevant. 

Interest on late payment 

Interest on late payment is a charge provided for in tax legislation, the purpose of which is to encourage timely payments, compensate the exchequer for late payment and to ensure equity for those taxpayers who do make their payments on time. 

From mid-September, Revenue intends resuming the collection of interest on late payment, with automated interest warning notices for VAT and PREM late payment issuing for July 2023 periods onwards. Interest charges on late payment were suspended in March 2020 in conjunction with the introduction of certain public health measures. Where subsequent late payments occur following the warning notice, interest will be charged on any future occurrences of late payment, and a standard notice will issue to taxpayers outlining the Interest on late payment charge.  

Change to acceptance of certain card types for tax payments  

From 1 October 2023, Revenue will no longer accept commercial credit cards for payment of tax. A warning message will display to the taxpayer on the online payment screens to advise that this card type is not accepted. Revenue continues to accept personal debit and credit cards in addition to commercial debit cards. Revenue advises that where a taxpayer is unsure of their card type, they should contact their card provider to confirm their card type.  

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