Mandatory e-Filing
Judging by the media coverage, the launch of the Revenue Commissioner's Annual Report became an opportunity to put the fear of God, Paul O'Connell style, among taxpayers. However, slipping almost unnoticed through it all was the publication of Revenue's consultation paper on mandatory electronic tax payments and filing.
Those of us dealing in the real world of tax compliance won't have been overwhelmed with the news of REAP usage, nor indeed of suggestions that Revenue would be seeking enhanced information gathering powers – there's nothing new there.
What is new are the long flagged plans on mandatory electronic filing. In brief summary, the proposals are:
A two stage process. Stage 1 would involve LCD cases and Government Departments, with mandatory eFiling and ePayment taking effect for returns and payments due after 1 January 2009. Stage 2 would involve larger companies, defined as those over the Audit Exempt Threshold (broadly turnover of more than €7.3m and net assets of more than €3.65m) with mandatory eFiling and ePayment taking effect for returns and payments due after 1 January 2010.
A general extension to existing filing and payment deadlines – between 7 and 12 calendar days depending on the tax and the month. It is suggested that this extension might be granted earlier than the introduction of mandatory eFiling and ePayment.
There is no suggestion that taxpayers other than companies might immediately come within the scope of mandatory eFiling and ePayment – individuals are omitted from the Stage 1 and Stage 2 proposals. Revenue recently announced the introduction of their new assessing system, featuring as it does what they describe as enhanced notices of assessment. It would seem that the notices of assessment for income tax purposes will be with us for some time to come.
However it seems that some consultation has already taken place, and also that an extension to the use of facsimile Forms CT1 for accounting periods up to and including 31 March 2008 (return due date 21 December 2008) is being offered (though of course the one does not imply the other). The phasing out of facsimile forms had previously been an article of faith with Revenue.
Revenue tell us they are “interested in hearing the views of practitioners, taxpayers and other interested parties on the proposals”. Submissions are requested before 16 June 2008.
CCAB-I has already made clear to Revenue its concerns in relation to mandatory ePayment and eFiling.