I propose to take Questions Nos. 311 to 314, inclusive, together.
The Tax Debt Warehousing scheme has offered valuable and practical liquidity support to businesses during the COVID pandemic and continues to support businesses as they recover from the impacts of the pandemic and increased energy prices. It has assisted businesses with their cash-flow during difficult trading periods, preventing business failure. The objective of this scheme is to allow firms help to recover thereby helping to guarantee their long-term economic viability and survival.
The scheme applied to VAT debts, PAYE (Employer) debts, certain self-assessed income tax debts and overpayments of both the Temporary Wage Subsidy Scheme (TWSS) and the Employment Wage Subsidy Scheme (EWSS).
The scheme allowed for the parking of the debt at 0 per cent interest up to 31 December 2022 (or 30 April 2023 for those in the extended scheme). A significantly reduced interest rate of 3 per cent, as opposed to the general interest rate of 10 per cent (or 8 per cent for income tax underpayments), applies from 1 January 2023 on the warehoused debt (or from 1 May 2023 for those in the extended scheme).
The scheme was automatically available to businesses and individuals that are managed by Revenue’s Business and Personal Divisions. Revenue’s Business Division manages enterprises with an annual turnover less than €3 million, which accounts for the majority of business taxpayers. Revenue’s Personal Division deals with all business entities with no trade or professional income such as trusts, charities, including NGOs, and sporting bodies. The scheme was also available on application to larger businesses managed by Revenue’s Large Corporates and Medium Enterprises Divisions, where such businesses were adversely impacted by the pandemic, and included a small number of individuals in Revenue’s High Wealth Division.
I am advised that Revenue does not record data by the category of NGO. In order to extract data which is as close as possible to the NGO sector, all cases with the Approved Charitable Body designation have been set out below in tabular form, along with the business activity sector in which they operate.
Breakdown by sector of tax liabilities warehoused by approved charitable bodies under the debt warehousing scheme:
Sector
|
Amount
|
Q Human health and Social Work activities
|
€3,782,166.36
|
S Other services activities
|
€1,327,445.21
|
R Arts, entertainment and recreation
|
€1,020,796.23
|
O Public administration and defence; compulsory social security
|
€840,814.17
|
G Wholesale and retail trade; Repair of motor vehicles and motorcycles
|
€518,570.44
|
P Education
|
€364,593.21
|
I Accommodation and food service activities
|
€240,729.07
|
N Administrative and support service activities
|
€179,041.01
|
L Real estate activities
|
€127,772.72
|
All other Sectors/Unknown
|
€61,748.20
|
Total
|
€8,463,676.62
|
A breakdown of tax liabilities warehoused by approved sporting bodies under the debt warehousing scheme is set out in the following table. (A breakdown by sport is not available).
Tax head
|
Amount
|
PAYE (Employers)
|
€724,585.28
|
Overpayments arising from the Employment Wage Subsidy Scheme
|
€169,675.21
|
Overpayments arising from the Temporary Wage Subsidy Scheme
|
€161,473.98
|
VAT
|
€80,424.52
|
Total
|
€1,136,158.99
|
The significant extension to the scheme announced in October 2022 means that businesses have until 1 May 2024 to make arrangements to repay their warehoused debt. Importantly, businesses are still able to avail of the reduced 3 per cent interest rate from 1 January 2023 when they come to pay the debt.
The total warehoused debt that has become uncollectible for any reason, including liquidation, examinership, cessation of trading, bankruptcy etc, is set out in the following tables by Division and by Sector:
Division
|
Amount
|
Business
|
€57,263,216.64
|
Medium Enterprises
|
€24,297,955.19
|
Large Corporates
|
€6,780,400.99
|
Personal
|
€147,637.32
|
Grand Total
|
€88,489,210.14
|
Sector
|
Amount
|
G Wholesale and retail trade; Repair of motor vehicles and motorcycles
|
€28,829,293.61
|
F Construction
|
€15,189,978.30
|
C Manufacturing
|
€8,672,420.14
|
J Information and Communication
|
€8,287,826.30
|
I Accommodation and food service activities
|
€7,221,843.26
|
H Transportation and Storage
|
€6,137,544.12
|
M Professional, scientific and technical activities
|
€3,836,745.85
|
N Administrative and support service activities
|
€3,455,224.68
|
L Real estate activities
|
€1,248,112.58
|
S Other services activities
|
€1,225,043.89
|
K Financial and Insurance Activities
|
€1,175,849.17
|
E Water supply; Sewerage, Waste management and remediation activities
|
€815,464.11
|
P Education
|
€766,419.32
|
R Arts, entertainment and recreation
|
€751,908.06
|
Q Human health and Social Work activities
|
€603,851.03
|
O Public administration and defence; compulsory social security
|
€122,064.10
|
A Agriculture, forestry and fishing
|
€116,548.73
|
All other Sectors/Unknown
|
€33,072.89
|
Grand Total
|
€88,489,210.14
|
Businesses are reminded on an ongoing basis that it remains a key condition of the Tax Debt Warehousing scheme that current liabilities are filed and paid on time. Revenue is actively engaging with businesses in the scheme to ensure they are complying with this key condition in order to retain the benefits of the scheme. However, where there is a continued lack of engagement and persistent non-compliance with current tax obligations, businesses will lose the benefit of the debt warehouse scheme.
At the end of September 2023, there were 11,816 businesses/individuals with warehoused debts totalling €312 million that had their warehouse status revoked due to persistent non-compliance with the scheme conditions. Where a business addresses their non-compliance issues and brings their current taxes up to date, the business can have its warehouse status reinstated.
Where payment difficulties arise, particularly in relation to current tax obligations, I am assured that Revenue will work proactively with businesses who engage early to resolve these payment difficulties.