Legislative footing for the debt warehousing scheme, announced on 2 May 2020, is set out in the Act. In addition, Revenue published the Information booklet on: Warehousing of tax debts associated with COVID-19 and reduced interest rate on other tax debts.

The debt warehousing scheme provides for the ‘warehousing’ of PAYE (Employer) and VAT debts associated with the COVID-19 crisis on an interest-free basis for a period of 12 months. Revenue set out the general terms of the scheme in its Information booklet. As of 6 August, approximately 70,000 businesses have availed of the scheme and €1.9 billion of tax debt has been warehoused under the scheme (€1 billion of PAYE Employer debt and €898 million of VAT debt).

Correspondence will issue to Business and Personal Division customers in September to inform them of their inclusion in the warehousing scheme. Other businesses, whose tax affairs are dealt with by Revenue’s Larger Corporates and Medium Enterprises Divisions, can access the scheme by application to either:

• the Revenue Branch normally dealing with the business’s tax affairs, or
• the Collector-General’s Division.

These businesses must satisfy Revenue that they are unable to pay PAYE (Employer) and VAT debts due to the COVID-19 related restrictions. Access to the warehousing scheme is conditional on the taxpayer quantifying their tax debt through submission of all outstanding returns.

A detailed table on page seven of the booklet identifies the periods for which debts can be warehoused and the movement through each of the phases relative to the month that the business resumed trading. A debt warehousing FAQ section commences on page eight of the booklet. You can access the Information booklet through the Revenue website.

Businesses availing of the debt warehousing scheme will qualify for a tax clearance certificate if they otherwise meet the normal qualifying conditions.