All VAT-registered traders are required by Regulation 24(1) of the Value-Added Tax Regulations 2010 (SI No. 639 of 2010) to submit a VAT Return of Trader Details (RTD) on an annual basis, following the end of the annual VAT accounting period.

Until recently, VAT RTD functionality in ROS was limited relative to that available for other returns. Among other issues, outstanding RTDs were not included in the list of outstanding returns, RTDs submitted through ROS could not be subsequently amended, and the ROS Returns screen showed the date of the VAT3 period in which an RTD was issued rather than the actual period of the RTD.

As part of the ongoing redevelopment of the VAT RTD by Revenue, a package of enhancements to further integrate RTD functionality in ROS was implemented in April 2016. This development does not change any of the existing arrangements for processing RTDs, but provides the following enhancements to the user experience in ROS:

• A facility to amend a VAT RTD already submitted through ROS, making the previous submission inactive;
• A validation check is performed against VAT3s filed during the period of the RTD where a Nil RTD is entered. If there are positive values in the VAT 3 returns for the relevant period, the RTD will be rejected with a message notifying the filer of same;
• Inclusion of the VAT RTD return in the list of outstanding returns for Agent/User. Previously, the RTD was not shown on this list when it was outstanding;
• Update of the “ROS Returns” screen to display the correct dates for the VAT RTD period. ROS previously displayed the dates of the last VAT3 period rather than the dates of the VAT RTD period in the “Returns” list screen.

As notified in eBrief No. 51/14, when a customer files a claim for repayment/refund of credit under any tax-head and there is an outstanding VAT RTD with a due date within the previous 12 months, then that repayment/refund will be automatically withheld. The outstanding VAT RTD and any other outstanding returns will be notified to the customer in a ‘Notice of Returns Outstanding’ letter issued by the Collector-General.

Outstanding RTDs for all periods will be displayed for each customer in ROS. Accordingly, a relatively large number of outstanding Returns may be listed in cases where Customers or their agents have not met the requirement to file an RTD annually for each VAT-registered case. As noted above, only outstanding RTDs which were due on any date within 12 months of the claim date will automatically result in a repayment being withheld. Outstanding RTDs listed in ROS from previous periods are shown for information, as Returns which are outstanding for up to six years may, in specific circumstances, be requested by Revenue officials in the course of a compliance intervention as provided in S.84(3) VATCA 2010.

Revenue is currently reviewing the possibility of introducing a rule in ROS which will only display outstanding RTDs with a due date which is less than six years from current date. This would have the effect of removing all outstanding RTDs listed with a due date falling before 2010 or earlier i.e. outside the six-year document retention period as specified in S.84(3) VATCA 2010.

Source: Revenue Commissioners. www.revenue.ie. Copyright Acknowledged.