Chartered Accountants Ireland, as a member of CCAB-I, made its pre Finance Bill 2013 submission to the Minister for Finance. In the submission we suggest some necessary amendments to the system which could be implemented in the context of Finance Bill 2013.

The points made in the submission include:

• Remove the EIIS and Seed Capital Relief from the list of tax reliefs subject to the High Income Earners Restriction
• Tailor the EIIS and Seed Capital Relief to provide a facility for company owner/managers to invest in their company
• Extending the EIIS to professional service companies
• As part of the proposed R&D regime review we call for improvements to the tax credit relief so that they can benefit the average employee working in the R&D sector.
• Thorough reform of the Close Company Surcharge regime
• The VAT turnover threshold for the Cash Receipts basis of accounting should be increased further
• The pension fund withdrawal option should also extend to PRSA and RAC contributions
• We note the numerous concerns raised by our members over the last year in respect of Revenue's right to require surety in the form of a bank guarantee or cash payment before allowing VAT refunds or VAT registrations to take effect (section 99(3) and 109 VATCA 2010).

In the submission we stress urgency for consultation on reform of the Appeal Process. Chartered Accountants Ireland first expressed concerns with the need to modernise the Appeal Process at a meeting with Minister Brian Hayes in late 2011 and again in our submission on the matter which was made last summer. We also made a further call in our Pre-Budget 2013 submission for commencement of consultation.

CCAB-I Pre-Finance Bill 2013 submission is re-published in part on here.

At the time of writing Finance Bill 2013 is expected to be published on Wednesday 13 February. The March issue of tax.point will include a feature article on the key measures of the Bill as well as Chartered Accountants Ireland's commentary.