ICAI, as part of CCAB-I, has written to the Minister for Finance to point out problems with the Revenue Regulations governing mandatory electronic filing.

The Regulations set out the categories of company which will be obliged to file and pay electronically with effect from 1 January 2009 initially, and 1 January 2010 subsequently. The Regulations fail to clarify the position for small companies which are not entitled to avail of the Audit Exemption Threshold. They leave open the possibility of retrospective application of mandatory electronic filing where the company fails to meet the Audit Exemption requirements through a late filing of the return to the CRO.

Regulations which give effect to severe penalties should be clear in their application, and this is not the case here. The letter is reproduced at Section 2.02.

Remaining on matters electronic, we understand that Revenue is to relaunch its own website www.revenue.ie involving a major redesign. ICAI has written to Revenue asking them to ensure that it is not launched at or near a major filing deadline, such as 31 October, 17 November or 21 November.