If further mandatory eFiling is introduced along the lines proposed in Revenue's consultation paper, every self assess–ment taxpayer will in effect be obliged to use Revenue Online Service (ROS) for all filing and payment.

Revenue's other current consultation, on mandatory disclosure of tax planning schemes, is refreshingly honest in its statement of intent – Revenue want to know as early as possible about schemes so that they can be closed down. The reasons offered for this consultation are considerably less transparent. Instead there's worthy sentiment expressed about real and tangible benefits for taxpayers, simplification and an extrapolation of one of the recommendations of the Commission on Taxation.

Cutting to the chase however, the real reason for seeking universal mandatory eFiling is to save public service costs. Revenue possibly has the worst of both worlds where filing and payment are de-coupled. It is considerably more time consuming for the Collector General's office to deal with a hybrid electronically filed return and a cheque payment than an electronically filed return and an Electronic Funds Transfer. In fact, in processing terms, it's probably cheaper for the Collector General to deal with a paper return and cheque than the hybrid. At least the cheque and return are delivered together.

Accountants will correctly view with some scepticism a further consultation on mandatory eFiling. Consultations surrounding the first phase of mandatory eFiling were distinguished by Revenue's almost total disregard for the observations made by the various representative bodies. Even technical shortcomings in the proposals brought to Revenue's attention were only acknowledged after the mandatory regime was introduced – eBrief 03/10 refers.

According to the consultation document, to be found on here, from 1 January 2011 all companies, partnerships, trusts and most self assessment cases will be required to file and pay electronically. 2012 would see the inclusion of all VAT registered individuals and all taxpayers making anything other than the most standard tax relief claims. By 2013, it's hard to see how anyone with a statutory obligation to furnish any return will be excluded.

Chartered Accountants Ireland will welcome any views you might wish us to make on your behalf to Revenue.