Important Notice To Taxpayers Availing of the Tax Warehousing Scheme

Revenue have announced that at the start of April 2022, they will issue a notice to all taxpayers who are availing of the Debt Warehousing Scheme (the “Scheme”).

What Will the Notice state?

Where a taxpayer has outstanding returns, the notice will include a schedule of outstanding returns for each applicable tax type and period. The notice will state that:

  • The outstanding returns must be filed before Revenue can confirm the schedule of warehoused debt;
  • If the outstanding returns are not submitted by 30 April 2022, the taxpayer will lose the benefit of the warehousing scheme (i.e. the debt will become payable immediately and the reduced 0% and 3% interest rates will be lost); and
  • Where any returns in relation to warehoused debt were on a “best estimate” basis, these returns must also be revised by the 30 April 2022 deadline.

Where a taxpayer has filed all returns due, the notice received will include a schedule of warehoused debt as at the date of the notice, broken down by tax type, period and the amount of debt warehoused.  The notice will state that:

  • Revenue will be in contact in December 2022 (or in April 2023 where the taxpayer has availed of the April 2022 extension) to discuss putting in place a tailored payment arrangement for the taxpayer’s warehoused debt;
  • The approach taken will be flexible and take into account the taxpayer’s financial circumstances;
  • There will be options available to make payments over a reasonable period of time;
  • Interest will be charged at a reduced rate of 3% per annum for the duration of the phased payment arrangement (rather than the standard rate of 8% or 10%); and
  • No interest will be paid on any warehouse debt paid off during the duration of 2022.

What Do You Need To Do?

Where the taxpayer has an active ROS Digital Certificate the notice will issue via ROS.  The remaining notices will issue via post. It is critically important that taxpayers who have availed of the Scheme check the notice that issues from Revenue to ensure that they have filed all tax returns so as to ensure that they remain in the Scheme. 

Taxpayers that have filed all returns due and have qualified for the extension of the Scheme to April 2022 are not required to take any action.  Such taxpayers’ VAT and Employer PAYE tax liabilities arising between 1 January 2022 - 30 April 2022 will be warehoused automatically when the returns are filed.

Taxpayers that have difficulty meeting their current tax obligations should engage early with the Collector-General’s Division to work with Revenue to agree a solution to enable their business to remain eligible for the Scheme.

How Can We Help?

If you have any questions in relation to the notice that issues from Revenue or with regard to how to put a payment arrangement in place with Revenue in respect of warehoused debts please contact a member of the McCann FitzGerald LLP Tax Team.

This document has been prepared by McCann FitzGerald LLP for general guidance only and should not be regarded as a substitute for professional advice. Such advice should always be taken before acting on any of the matters discussed.