Revenue Note for Guidance

The content shown on this page is a Note for Guidance produced by the Irish Revenue Commissioners. To view the section of legislation to which the Note for Guidance applies, click the link below:

Revenue Note for Guidance

77. Authorisations in relation to filing dates


The purpose of this section is to allow for VAT returns less frequent than the normal bi-monthly system. It provides for a variation on the normal requirement so that, at the discretion of the Collector-General, certain traders (in practice, mainly small-scale traders) may be permitted to make returns and payments at less frequent intervals than normal (not exceeding twelve months).

In practice, accountable persons with an annual liability of €3,000 or less may be authorised to submit a return for a six-monthly period and, where the liability is between €3,001 and €14,400, accountable persons may submit a quarterly return.

When a return is lodged in respect of an accounting period and in accordance with the conditions applicable, the trader is deemed to have complied with the general requirement in regard to each of the two-monthly taxable periods that make up his/her accounting period.


(1) Subsection (1) defines ‘accounting period’ and limits it to a period not exceeding 12 months.

The subsection also allows annual remitters and taxpayers under the direct debit scheme who submit one VAT return per year to align the date of their annual VAT return with the date of their own commercial accounting year. The term ‘authorised person’ is also defined as an accountable person authorised under the section.

(2) Subsection (2) applies notwithstanding the normal rules:

  • (2)(a) Paragraph (a) empowers the Collector-General to make authorisations unless the accountable persons object, in which case they will remain on the normal two-monthly system of returns and remittances.
  • (2)(b) Paragraph (b) provides that an authorised person may furnish a return and remittance covering a period consisting of a number of taxable periods (maximum 6).
  • (2)(c) Paragraph (c) provides that, in the case of a person authorised to account for VAT by monthly direct debit, the amount of such remittance is the balance of tax remaining after deducting the direct debit payments made by him/her.
  • (2)(d) Paragraph (d) provides that the concept that liability to tax and deduction of input tax relates to each taxable period comprised in the accounting period is maintained. The maintenance of that concept is necessary having regard, in particular, to the Revenue preferential status in bankruptcy and liquidation – see Taxes Consolidation Act 1997 sections 960O and 960P, which refer to a liability to VAT for the taxable periods which ended in the 12 months immediately prior to the date of bankruptcy or winding-up.

(3) Subsection (3) gives details of certain matters that the Collector-General may take into account when issuing an authorisation. These are set out in paragraphs (a) and (b).

  • (3)(a) Paragraph (a) establishes that there will be no threat to revenue and that the accountable person concerned will meet his/her obligations in relation to the authorisation.
  • (3)(b) Paragraph (b) provides that the accountable person must be registered for VAT for at least one year prior to the year in which the authorisation has effect and that he/she must have made all his/her returns in respect of the preceding taxable periods.

(4) An authorisation can be issued with or without conditions.

  • (4)(a) Paragraph (a) enables the Collector-General, taking into account the matters outlined in subsection (3), to issue an authorisation subject to any conditions which he/she deems fit, and to set out those conditions in writing.
  • (4)(b) Paragraph (b) establishes that, without prejudice to any conditions which might be laid down by reference to paragraph (a), the Collector-General may require an authorised person to make payments on account between the 10th and 19th day from the end of each taxable period in his/her accounting period, except for the last taxable period.

(5) An authorised person may be required to agree to a schedule of amounts with the Collector-General to be paid through direct debit. The amounts specified on the schedule should amount to the person’s best estimate of the annual liability. If the total of the direct debit payments are not, or are not likely to be, sufficient to cover the person’s annual liability, the person should agree a revised schedule with the Collector-General and adjust the direct debit amounts accordingly.

Under the direct debit system, any balance of tax remaining is submitted with the end of year VAT3 return. Note that where insufficient amounts are paid by direct debit which result in the balance of tax payable with the return amounting to 20% or more of the trader’s annual VAT liability, the trader is liable to an interest charge back to mid-point of the year – see section 114(3).

(6) The Collector-General has power to terminate, by notice in writing, an authorisation. The Collector-General is obliged to terminate an authorisation where requested to do so.

(7) Subsection (7) gives details of certain matters that the Collector-General may take into account when terminating an authorisation. These are set out in paragraphs (a) and (b).

  • (7)(a) Paragraph (a) establishes that the Collector-General may terminate an authorisation where he/she is no longer satisfied regarding security of the tax.
  • (7)(b)(i) Paragraph (b)(i) provides that the Collector-General may terminate an authorisation where the accountable person concerned supplied, or there was supplied on his/her behalf, false information in order to receive an authorisation.
  • (7)(b)(ii) Paragraph (b)(ii) provides that the Collector-General may terminate an authorisation where the accountable person fails to submit his/her return and remittance in time or does not comply with any conditions laid down by the Collector-General in relation to the authorisation.

(8) Where an authorisation is terminated, the authorised person has 14 days in which to submit a return in respect of outstanding accounting periods or part thereof.

(9)(a) An authorisation is deemed to be terminated where the authorised person—

(i) ceases to trade,

(ii) being a body corporate, goes into liquidation, or

(iii) is no longer an accountable person, e.g. continues to trade but supplies made are exempt from VAT, or is no longer registered for VAT, i.e. his/her turnover falls below the limit above which registration is compulsory and he/she opts to deregister, or he/she is no longer able to carry on business due to bankruptcy or death.

(9)(b) Where an authorisation is withdrawn, the accountable person will, in relation to any taxable period for which no return or payment has been made, comply with the terms of section 76 as if the authorisation had not been issued.

(9)(c) Paragraph (c) allows for a personal representative of the authorised person to be treated as the accountable person concerned for the purposes of this subsection.

Relevant Date: Finance Act 2020