Revenue has made C&E TAN Reports available on ROS.

During 2023, The Irish Tax Institute, via its Tax Administration Liaison Committee (“TALC”) requested Revenue’s systems be updated to enable tax agents to access client Customs & Excise (“C&E”) reports which are required to assist in completing Postponed VAT Accounting (“PVA”) entries on the VAT3 return.

Revenue have now confirmed that with effect from 16 June 2024, Tax agents will have direct access to client’s C&E reports on ROS.  Prior to this date agents were unable to obtain such information via their ROS access.   This means that agents will now have full visibility of declarations where PVA was applied for a selected period. This report is also known as the TAN report.

The information available to tax agents will be limited to reports from 16 June 2024. In order to view historic C&E reports, these will need to be requested separately from the client.

Background

PVA was first introduced in January 2021 and is available to all traders that are registered for VAT and C&E. PVA arrangements may be applied to all imports from third countries, including Great Britain (excluding Northern Ireland) and while not compulsory, proves to be cash flow beneficial for businesses.

PVA allows for import VAT to be accounted for and recovered on the same VAT Return, whereas historically, import VAT was generally remitted to Revenue at the point of entry prior to the release of the goods, with VAT recovery only available via the VAT return for the period in which the import arose.

If you were already registered for VAT and C&E when the Brexit transition period ended on 31 December 2020, you should not need to apply separately for PVA – you would have been automatically entitled to avail of the facility. If you are VAT registered but weren’t registered for C&E on 31 December 2020, you must register for C&E and obtain an Economic Operators Registration Identification (“EORI”) number.

PVA Compliance Obligations

The amount of postponed VAT stated in the TAN report on Revenue must be included in the additional field for postponed accounting “PA1” on the VAT3 Return. The import VAT is then accounted for at T1 and T2 (subject to standard VAT recovery rules).

It is important to note that Single Administrative Document (“SAD”) is a mandatory customs document that must be used for all import and export operations. Revenue at any time may request to review the SAD and therefore the information included in the document must be accurate and complete.

The amount of import VAT payable should be stated on the SAD document as well as the VAT number of the entity seeking to benefit from PVA. This information is also reflected on the TAN report and included on the VAT3 Return under PA1. It is only the Importer of Record or “Consignee” of the goods whose Irish VAT number is stated on the SAD can claim PVA and as such, it is important to ensure correct procedures are being followed.  

If you require any assistance in this area, RSM can help by carrying out a review of your C&E statements, SAD and VAT3 returns to ensure correct procedures are being followed.

Should you have any queries in respect of the above or the implications for your business, please contact Barry McNamara or Áine Casey.