Revenue announce extension to debt warehousing 16 December 2022

Warehouse extension 2022

In December 2021, the Debt Warehousing Scheme (DWS) was extended for some businesses. The businesses must:

• already be eligible for warehousing
• and
• have a valid claim during the period from 1 January 2022 to 30 April 2022 for any of the following Government COVID-19 Support Schemes:
• Employment Wage Subsidy Scheme
• Covid Restrictions Support Scheme
• other Government Covid-19 Support Schemes (details available in Section 4 of the Information Booklet on Debt Warehousing).

For businesses who qualify for the extension, warehouse period dates extend as follows:

Period 1 end date

Period 1 ended on 30 April 2022. All returns for qualifying taxes which fall in Period 1, will be entered into the warehouse.

Period 2

Period 2 is a one-year period which runs from 1 May 2022 to 30 April 2023 in the case of customers entitled to the warehouse extension. No interest is applied to the warehoused debt during Period 2.#### Please see below for rules

Period 3

Period 3 starts when Period 2 ends, that is, 1 May 2023. You have until 30 April  2024 to agree a Phased Payment Arrangement with Revenue for the warehoused debt. However, you can make interim payments towards your warehoused debt at any stage. Interest will be applied from the start of Period 3 until the final payment date at a rate of 3%. 

###What this means is

Taxpayers who availed of the DWS also need to engage with Revenue in advance of the new deadline of 1 May 2024 to:

1. Settle all outstanding liabilities by end of 2022 (at 0% interest);
2. Settle all outstanding liabilities between 1 January 2023 – 30 April 2024 (at 3% interest); or
3. Establish a Phased Payment Arrangement (PPA) to settle the outstanding liabilities within such period as may be agreed with Revenue after the 1 May 2024 deadline (at 3% interest).  A PPA generally requires a minimum down payment of 25% or 40% of the outstanding liabilities.

Revenue should have written to you in December outlining how outstanding liabilities deferred under the DWS may be repaid.

I would suggest engaging with the revenue thorough my enquires in relation to this to make sure all relevant taxes are covered

Qualifying terms and conditions

The terms and conditions which apply to the warehousing of debt for each tax type are that:

• all tax returns must be filed so that the debt is quantified
• current taxes must be paid as they fall due.

Additional terms and conditions

Income Tax (IT)

There are additional terms and conditions applied to the warehousing of IT.

IT payments which fell due on 31 October 2020, and those falling due on 31 October 2021, may avail of the Debt Warehousing Scheme (DWS). This is subject to certain criteria as outlined below.

2019 IT Return

• You must have filed your 2019 IT Return by the relevant deadline dates.
• You must expect your total income for 2020 to be at least 25% less than your total income for 2019. A declaration of this expectation must be made on your 2019 IT Statement of Net Liabilities. 

2020 IT Return

• You must have filed your 2020 IT Return by the relevant deadline dates.
• You must expect your total income for 2021 to be at least 25% less than your total income for 2019. A declaration of this expectation must be made on your 2020 IT Statement of Net Liabilities. 

Schedule E PAYE liability (2020 IT Return only)

You may be entitled to warehouse some of your IT liability if you are a director or employee with a material interest in your employer company. This applies to Schedule E PAYE liability for your 2020 IT Return only.

You must make a declaration on your 2020 IT Statement of Net Liabilities that you are not: 

• entitled to IT warehousing as your income is more than 75% of 2019 income
• able to claim relief under S997A TCA as your employer has warehoused their PAYE (IT) liabilities.

Terms and conditions for the Temporary Wage Subsidy Scheme (TWSS)

It is possible to warehouse your Temporary Wage Subsidy Scheme (TWSS) and Employment Wage Subsidy Scheme (EWSS) repayment. For this, you must be able to show that your business is unable to repay the excess payment you received. 

Note

Failure to comply with the terms and conditions of warehousing will result in your removal from the scheme. All outstanding balances may be enforced and interest at the full statutory rate will be applied.

 Courtesy https://www.revenue.ie/en/starting-a-business/paying-your-tax/debt-warehousing/index.aspx