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iXBRL: practical filing updates

Revenue has published confirmation of their position on a number of iXBRL practical filing issues. These issues include; the requirement for the detailed trading and profit and loss account, the due date for filing iXBRL returns, filings for long accounting periods, and draft financial statements.

Detailed trading and profit and loss account

Revenue will accept iXBRL returns filed without a Detailed Trading and Profit and Loss Account (DPL) up to 30 November 2015. In eBrief No. 78/15 Revenue confirms that with effect from 1 December 2015, it is a Revenue requirement that the fully tagged DPL is included with every iXBRL return filed.

Revenue has published FAQs on the DPL which deal with the items they require to be tagged, the format of the DPL and why they are requesting a DPL be included in the iXBRL return.

Due date for iXBRL returns

If you have filed iXBRL returns and within the 21 day iXBRL filing period, you may have received an assessment with a late filing surcharge imposed. Following representations made by us, Revenue has confirmed to us that Revenue Online Service (ROS) will be amended to deal with such a surcharge.

Members notified us that assessments were issuing from Revenue with a late filing surcharge in cases where the iXBRL returns were filed within the 21 day iXBRL filing period. As a reminder, iXBRL returns are expected to be filed within 21 days of the filing of the form CT1 or after the due date for the return, whichever is later.

Revenue informed us that the 21 day iXBRL filing period on ROS ran from the paper filing deadline of the 21st of the month and not the ROS corporate tax filing deadline of the 23rd of the month. We made representations to Revenue that this was not in line with practice and previous guidance on iXBRL filing.

Revenue advised that where a surcharge was applied due to iXBRL returns filed in the two subsequent days (between the 21st day and the 23rd day) that such surcharge would be removed on contacting the tax district. We highlighted to Revenue the practical difficulties of this approach.

ROS will be amended to provide that a late filing surcharge for iXBRL returns will not apply until the 21 day iXBRL filing period, running from the ROS filing deadline of the 23rd of the month, has expired. We understand that it will take some time for ROS to be updated. In the meantime the advice for dealing with surcharges due to iXBRL filings is to contact the relevant tax district.

You are reminded of the Revenue FAQ on iXBRL sanctions which states “Revenue will not impose late filing surcharges or other penalties in respect of errors in the creation or filing of iXBRL tagged financial statements for a period of 2 years following mandation where a taxpayer has made reasonable efforts to comply with their obligations”.

It is confirmed in eBrief No. 78/15 that “an additional 21 days after the return filing date (i.e. 21st or 23rd day as appropriate) is applied to the filing of iXBRL financial statements”.

Long accounting periods

Following representations made by us to Revenue on the practical iXBRL filing issues for companies with a long accounting period, Revenue has confirmed in the eBrief that the iXBRL return, reflecting financial statements for that long period, should be filed against the second corporation tax filing period (the short period) only.

Draft financial statements

We have also been engaging with Revenue on the practical issues of filing draft financial statements in iXBRL. Revenue’s position is that if you are “satisfied that the only issue pending is that the financial statements have not been signed-off by the director(s), then it is in order to file the draft/provisional accounts without prior permission from Revenue. In these circumstances, there is no need to re-submit the iXBRL financial statements, when they are signed-off later [unless the draft statements are different to the final ones submitted].” If there are any other issues for filing in draft then you must contact Revenue in advance of filing (per the eBrief).

Revenue has also updated their FAQs to include the above clarifications.

Revenue eBrief No. 78/15 is published here.

We continue to engage with Revenue on iXBRL and you will be kept informed via our electronic newsletters. You can visit our iXBRL web centre for further updates and reading on iXBRL.