We are writing to you as Revenue’s Chair of Main TALC. We have put forward an agenda item on the topic of tax compliance deadlines for discussion at next Tuesday’s meeting.

In advance of the meeting, it may be helpful for Revenue to consider the matter as follows.

The four professional accountancy bodies which comprise the CCAB-I are fielding concerns from our members daily regarding the corporation tax deadline of 23 September and the income tax deadline of 12 November. Accountants in small to medium-size practices are facing a crisis this Autumn in terms of getting tax returns filed by the deadlines on behalf of their clients.

The key problem for our members is that they are working at least eight weeks behind schedule due to work time lost during the lockdown restrictions, staff unable to work full hours over the summer due to childcare constraints and an increased workload supporting clients with the wage subsidy schemes, other government grants and subsidy applications, and revised credit arrangements with banks and landlords.

The suspension of the surcharge on the late filing of CT1s and the relaxation of iXBRL account filings in the context of the 23 September deadline are very important to allow accountants time to assist their client in filing Form CT1s. We ask that the non-submission of a Form CT1 on time for the 23 September deadline does not impact a taxpayer’s tax clearance or access to debt warehousing arrangements. The surcharge respite for Form CT1s makes provision to preserve reliefs, such as loss relief and group relief, which would otherwise be restricted under section 1085(2) TCA 1997 and we ask that this approach is extended to include the temporary loss relief measure under section 396D TCA 1997. There are certain elections that need to be made on filing a return by the due date and we ask that these elections are not prevented from being effective where the Form CT1 is not filed on time.

The challenges facing small to medium – size practices are even greater for the upcoming income tax deadline as currently there is no measure in place to suspend surcharges on the late submission of income tax returns due for 2019. We appeal to Revenue to introduce a surcharge suspension for the 12 November deadline, and again we ask that returns filed late do not impact a taxpayer’s tax clearance, access to the debt warehousing scheme or loss relief under section 395B TCA 1997.

Revenue currently has suspended field audit work and we ask that desk audit activity which is time bound in terms of getting a response back to Revenue is also suspended until the end of November so accountants can focus all their time and energy in getting tax returns for clients filed on time.

Accountants will make every effort to ensure that as many tax returns as possible are filed on time, but due to the extraordinary circumstances brought about by COVID-19, there will be instances where it is just not humanly possible to make the deadline. A cohesive respite in the application of surcharges will be of immense importance to accountants who find themselves in difficulty.

We acknowledge all the helpful measures already instigated by Revenue and trust that Revenue will go one step further to help accountants and tax agents in these difficult times.

We look forward to discussing this matter with you at Main TALC on Tuesday 8 September.