Who should submit financial statements in iXBRL format with Revenue?
Applicability of filing annual financial statements in iXBRL format with Revenue
The obligation to file electronic Financial Statements was introduced on a phased basis. All Corporation Tax payers meeting the Phase I or Phase II criteria are affected by the changes. These include
- Irish Tax Resident Companies
- Parents and Subsidiaries
- Branches/Agencies of Non-Resident Companies
- Companies not bound by the Companies Acts
Starting from October 2013, Revenue has implemented a phased introduction of the requirement to file electronic Financial Statements as part of the Form CT1. It is expected that there will be a gradual transition until eventually all Corporation Tax payers will submit their Financial Statements in iXBRL format.
The table below sets out who is required to file iXBRL Financial Statements and when :
|Commencement Date||iXBRL Filing|
|23 November 2012||Voluntary for all Corporation Tax payers|
|1 January 2013||Voluntary for all Income Tax payers|
|1 October 2013||Phase I
Mandatory for customers of Revenue’s Large Cases Division filing
Corporation Tax returns (except Section 110 Securitisation Special
(i) on or after 1 October 2013
(ii) with respect to accounting periods ending on or after 31December 2012
|1 May 2014||Mandatory for customers of Revenue’s Large Cases Division Section
110 Securitisation Special Purpose Vehicles filing Corporation Tax
(i) on or after 1 May 2014
(ii) with respect to accounting periods ending on or after 31 July 2013
|1 October 2014||Phase II
Mandatory for all Revenue customers filing Corporation Tax returns, except those meeting iXBRL deferral criteria*,
(i) on or after 1 October 2014
(ii) with respect to accounting periods ending on or after 31December 2013
|Later phases to be confirmed||Mandatory for all Corporation Tax payers not covered by Phases I &
The mandate may be extended in the future to some Income Tax filers.
*iXBRL deferral criteria
Entities excluded from Phase II filing
To be excluded from the Phase II filing obligation, a company must meet all three of the following criteria:
- The balance sheet value of the company does not exceed €4.4 million; and
- The amount of the turnover of the company does not exceed €8.8 million; and
- The average number of persons employed by the company, calculated in accordance with s.317 of the Companies Act 2014, does not exceed 50.
Entities exempted from filing electronic Financial Statements with their Form CT1
Inactive companies and companies in liquidation may not be required to file electronic Financial Statements with their Form CT1. However, in exceptional circumstances, Revenue retains the right to request electronic Financial Statements from such companies.
Companies in liquidation
In general, it will be for Revenue Operational Branches to decide whether iXBRL Financial Statements in liquidation cases are required in addition to the Form CT1. The decision making process in this regard should be the same as is currently applied in waiving the obligation to file a Form CT1 electronically. Revenue will apply the following where a Form CT1 is filed:
Not a voluntary liquidation:
For companies in liquidation, where there are no net assets for distribution, Revenue will accept that an iXBRL return need not be filed and the “Extracts from Accounts” on the Form CT1 should be fully completed instead. However, Revenue retains the right to request that an iXBRL return is filed in specific cases. Specific requests for filing the iXBRL return are more likely to be made where the company is not compliant in respect of Form CT1 obligations up to the date of liquidation.
For companies in voluntary liquidation, where the net assets for distribution do not exceed €25,000, and provided that all obligations under company law and all tax related requirements have been fulfilled up to the date of liquidation, applications to waive the iXBRL filing obligation may be made on a case-by-case basis to the relevant Branch Manager. Where the application is accepted, the waiver of the obligation to file the iXBRL return will be noted on Revenue’s systems.
At present all companies that are registered in Ireland have an obligation under the Companies Act 2014 (previously Companies Act 1963) to prepare and make out accounts. Revenue is willing to waive the obligation to file Financial Statements in iXBRL format where a company is inactive. Revenue will classify a company “inactive” where there is no activity in the accounting period. It is considered that there is no activity in the accounting period and hence a company is not required to submit accounts in iXBRL format where the following conditions are met:
- No income or expenses on the Statement of Profit or Loss (annual CRO and audit fees can be ignored); and
- A Statement of Financial Position / Balance Sheet movement of less than EUR500, except in the first year after the company becomes inactive where it is paying off its trade creditors and has not been previously obliged to file Financial Statements in iXBRL format.
It may be noted that Companies not yet subject to mandatory iXBRL filing, as well as Income Tax filers, may still file electronically on a voluntary basis.
Where mandatory filing of the Financial Statements in iXBRL format applies and the 3 months have elapsed without the filing of Financial Statements in iXBRL format, the issue of a €1,520 penalty under section 917 EA (7) may apply.