Chartered Accountants Ireland is a membership body comprising some 28,500 Chartered Accountants across the globe and is the largest professional body of accountants on the island of Ireland. Two thirds of our members in Northern Ireland (c4,500 members) work in business and combined with our members in practice have been and continue to be at the forefront of helping businesses navigate the various Government supports introduced as a result of the COVID-19 pandemic. Our members also play a vital role in assisting businesses in meeting their tax compliance obligations.

Firstly, we wish to acknowledge the importance of the Government’s COVID-19 support measures introduced from March 2020, many of which have been implemented by HM Revenue & Customs (“HMRC”) including the enhanced Time to Pay arrangements now available for Self-Assessment tax debt announced in your September 2020 Winter Economy Plan. Since March 2020, HMRC has swiftly implemented practical and helpful measures to support businesses and taxpayers in these difficult times.

However, the rampant nature of the virus in recent weeks necessitating a further severe lockdown in all regions of the UK introduces insurmountable obstacles to self-assessed businesses and individuals in their efforts to meet the forthcoming 2019/20 Self-Assessment filing deadline on 31 January 2021. We are therefore writing to ask you to again respond to the evolving situation.

The pandemic has put immense pressure on businesses in meeting regulatory and reporting obligations due to workplace health and safety obligations, staff resourcing, illness and childcare/caring constraints and responsibilities and the challenges of social distancing.

The regulatory workload of businesses is already at least two months behind normal schedules due to the national lockdown in 2020 and further restrictions across the various regions introduced from October 2020 onwards. We are also aware of the very considerable demands on our tax authority at this time as HMRC channels COVID-19 supports to businesses and individuals. Practical measures can now be put in place by the Government to help businesses cope with regulatory obligations in these difficult times. It is therefore essential that swift and cohesive action is taken now to deal with the forthcoming 2019/20 Self-Assessment filing deadline of 31 January 2021.

Since September 2020, we have been engaging with your HMRC officials to discuss the difficulties businesses and accountants are experiencing in meeting the forthcoming deadline. Although the most recent update from HMRC on this issue sets out that late filing due to COVID-19 will be accepted as a reasonable excuse for late 2019/20 Self-Assessment returns (including when an accountant is delayed in filing due to the pandemic), this still means that HMRC will apply a penalty which must be then appealed by the business or their accountant. Handling such appeals adds to the workload and costs for businesses and HMRC alike.

Although accountants will make every effort to ensure that as many tax returns as possible are filed on time for businesses, due to the extraordinary circumstances of the pandemic, there will be instances where it is just not practically possible to make the deadline.

A short once-off extension of one month to the 2019/20 Self-Assessment deadline would help ease the pressures on businesses who may have the necessary information for the preparation of their return but cannot safely provide this to their accountant due to the ongoing public health restrictions. Many businesses have not been able to have their annual accounts prepared for the same reason.

Extending the filing deadline would also be of assistance to accountants who are already overwhelmed by their workload and would allow businesses and their accountants sufficient time to prepare and file returns in adherence with public health requirements. It would maintain the integrity of the self-assessment tax system more efficiently in an emergency year than the current delayed filing and subsequent appeal process.

We know that you are aware of the challenging time constraints on all of us and that you will give this matter careful consideration.