Revenue Code of Practice and, the need for self policing

Friday, September 15, 2017

by Nick Ryan

Following the introduction of the Revenue Code of Practice for Revenue Audit and Other Compliance the necessity for VAT registered businesses to increase their self policing of the tax has increased significantly.
With the draconian measures introduced covering the determination and imposition of penalties and the dramatic shift from discussion and negotiation to submission and imposition Revenue have clearly taken the upper ground over the tax payer and we have seen more and more instances of Revenue immediately seeking to impose the maximum penalty irrespective of the issue in hand or the level of VAT at stake.
In conjunction with his the rule of thumb over issuing assessments appears to also shifted away from considering the case on materiality and significance to assess, assess, assess.
This may be enough to exasperate the most considerate and obdurate of businesses but, when added into the mix Revenue’s sudden decline in providing opinions, or responding to a request other than by offering the business thirty days to make a full disclosure, this is forcing businesses to make a decision, either duck it and see or, take the matter into their own hands and seek outside specialist advice.
The former can lead to a very costly conclusion, the latter in itself can be a costly journey, sometimes resulting in a frustrating end when the business is no better off as the guidance provided does not suit what was required.
Let us accept one thing, the past is the past, if it is has happened then it is largely out of our control, where mistakes have been made then we can only proffer forgiveness and seek terms. What is important is now and the future.
The VAT Practice strongly recommend that a business look at its VAT throughput from a current perspective to determine whether if it is efficient in its administration, compliant in reporting and accounting and, on its use of rates, concessionary schemes etc. and, whether the VAT overall liability to the State can be minimised. In conjunction to this, there is a need to look at the impact of potential future opportunities, divergences, new lines and, possible market changes.
Cost is key, the VAT Practice can provide your client’s business with the level of input they require to provide them with an overview on their VAT accounting position including an appraisal of issues they might need to consider and, whether it is possible to minimise their VAT throughput through the implementation of any efficiency measures. The VAT Practice recommends that all businesses should consider a preliminary high level review to test for weaknesses and highlight issues of concern. This review can place a business in a position from which it can strategically consider the options and plan changes without the incurrence of a significant cost.
Like most things in life, businesses need to review their health status and VAT is one element where any illness or fragility can result in a significant, at times fatal, cost. The VAT Practice can provide a high level review covering the above for a fixed fee of €875 exclusive of VAT.
For more information, or to arrange a review for your client, contact the VAT Practice on +353 2388 38181 or info@thevatpractice.ie .

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