CCAB-I's post finance Bill written submission focuses on the key measures which require further consideration as the Bill passes through the Oireachtas. The Institute has also been in discussions with Revenue on the measures in the Bill through the TALC process.

The points in the submission include:

• Section 8 R&D Credit-Clarification is required on the ability to carry forward any relief unused by the employee and the operation of the clawback of the relief where credit is claimed in good faith by the employee, but subsequently withdrawn from the company.
• Section 12 FED-the requirement to be present for 10 consecutive full days in just one of the BRICS countries will hamper the success of the relief. Alternatively a requirement to spend a minimum required combined period in one or more of the BRICS over the course of a year is suggested.
• Section 14 SARP –The relief should be at least as attractive as the previous SARP. Additionally, measures are needed to ensure that the pre 2012 SARP is grandfathered for those already availing of this relief.
• Section 25 EII –to maximise the usefulness of this scheme, it is suggested that it be removed from the list of specified reliefs for High Income Earners.
• Section 113, Section 116 and Schedule 4 Self-Assessment provisions –CCAB-I will be discussing with Revenue through the Tax Administration Liaison Committee process how these new arrangements might work. Some revisions arising from this work will be brought to the Department of Finance with a view to their inclusion in Finance Bill 2013.

The CCAB-I Post Finance Bill submission is published on the Chartered Accountants Ireland website http://www.charteredaccountants.ie