The Tax and Duty Manuals Part 47-06-01 (Return Filing Dates – Forms 11 and CT1), Part 47-06-04 (Late Submission of Corporation Tax Returns – Restrictions of Claims to Relief) and Part 47-06-08 (Surcharge for Late Submission of Income Tax, Corporation Tax and Capital Gains Tax returns) have been updated for the COVID-19 concession on the surcharge for late submission of CT1 returns, iXBRL financial statements and loss relief restrictions for late filing of returns due. These concessions will be withdrawn on 1 July 2021.

The Tax and Duty Manuals reflect that the surcharge for late submission of CT1 returns and iXBRL financial statements, and the restrictions on loss relief for late filing of returns, are suspended between 23 March 2020 and 1 July 2021 where:

• the late submission of CT1 returns is for accounting periods ending from June 2019 to September 2020, and
• the late submission of iXBRL financial statements is for accounting periods ending from March 2019 to June 2020.

The Revenue website also reflects the above in relation to the application of late surcharges for late CT1 returns and iXBRL financial statements. Previously the website stated that surcharges were suspended until further notice.

A late CT1 return can be completed without the restriction of reliefs, such as loss relief and group relief where, in respect of an accounting period ending between June 2019 and September 2020, due by a date on or after 23 March 2020 but before 30 June 2021 –

• is filed late, but before 1 July 2021,
• is not a return that is deemed to be filed late under section 1084(1)(b) TCA, and
• the late filing is the result of COVID-19 circumstances.

Late filing surcharges and restriction of reliefs will apply where CT1s to which the extension applied, are not filed by 1 July 2021.

See eBrief No. 065/21 for further details.

Revenue previously confirmed in a press release that reminder notices will issue to companies with outstanding Form CT1s for an accounting period ending in the 6 months to 31 December 2019. If the Form CT1 remains outstanding, the company will no longer qualify for tax clearance and access to the EWSS and CRSS supports will be withdrawn. Revenue confirmed to the CCAB-I in a recent TALC meeting that the surcharge suspension for late iXBRL financial statements for accounting periods will also cease to apply from 1 July.

The CCAB-I noted, in our discussions with Revenue, that companies continue to have challenges establishing if the trade will continue as a “going concern” due to the disruption caused by COVID-19 and this in turn is presenting difficulties for officers of companies to sign off on company accounts. This issue will persist while Government restrictions continue and Form CT1s and iXBRL financial statements will be delayed consequently. Revenue will continue to keep the position regarding the late filing surcharge and iXBRL financial statements under review.