As part of the criteria to ensure that a company or individual is able to avail of the Tax Debt warehousing scheme introduced by Revenue due to Covid, all entities must ensure that current tax liabilities are filed and paid. Revenue recognise that this isn’t always feasible. Due to the difficulties some entities are experiencing, Revenue has enhanced its Phased Payment Arrangement (PPA) system to allow both warehoused debt and non-warehoused debt to be included in one PPA.

Revenue has confirmed that the standard down payment of 25 percent (40 percent where tax clearance is required) required to enter a PPA will also apply to warehoused debt. However, Revenue recognises the difficulties that many businesses are encountering and intends to be flexible and take account of the financial circumstances of the business concerned on a case-by-case basis where appropriate.

From our experience Revenues approach will be a balanced one seeking to secure a level of ongoing repayment that is reasonable and that affords each business a reasonable opportunity to clear the debts in the warehouse.

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