As previously advised in the January 2008 issue of tax.point, Revenue have published a “consultation document” on their imposition of electronic filing and electronic payment, initially on companies handled by Large Cases Division.

More than 85% of all self assessment cases are assisted by Chartered Accountants or other tax agents, so the implications of any procedural changes are significant. None of us do this work for the good of our health — tax compliance work must be commercially viable. Procedural changes which may impact on the time taken, and the risks involved, could prejudice the attractiveness of compliance work. For our members in business, there will also be procedure and risk implications as tax payment procedures migrate on-line.

ICAI is at present assembling any issues which members may wish to raise in the context of Revenue's mandatory eFiling and ePayment consultations. The initial feedback we are receiving is that members have no issues with eFiling requirements, and indeed by and large are comfortable with the ROS eFiling procedures. Electronic payments are a different matter, with views being expressed on:

• Difficulties in repairing incorrect payment amounts arising from clerical errors
• Revenue's capacity to deal with large numbers (as distinct from large value) of electronic payments
• The assignment of payments against tax heads
• Difficulties and delays generally in securing repayments of overpaid tax

We would also welcome members' comments on Revenue proposals to bring PAYE and VAT monthly/bimonthly payments to the same settlement date, generally the 26th of the month.

Please relay your comments to ICAI Tax Director Brian Keegan (brian.keegan@icai.ie).