Debt warehousing

Qualifying terms and conditions

The terms and conditions which apply to the warehousing of debt for each tax type are that:

  • all tax returns must be filed so that the debt is quantified
  • and
  • current taxes must be paid as they fall due.

Additional terms and conditions

Income Tax

There are additional terms and conditions applied to the warehousing of Income Tax.

Income Tax payments which fell due on 31 October 2020, and on 31 October 2021, could avail of the Debt Warehousing Scheme (DWS). This was subject to certain criteria, as outlined below.

2019 Income Tax Return

  • You must have filed your 2019 Income Tax Return by the relevant deadline dates.
  • You must have expected your total income for 2020 to be at least 25% less than your total income for 2019. A declaration of this expectation must have been made on your 2019 Income Tax Statement of Net Liabilities. 

2020 Income Tax Return

  • You must have filed your 2020 Income Tax Return by the relevant deadline dates.
  • You must have expected your total income for 2021 to be at least 25% less than your total income for 2019. A declaration of this expectation must have been made on your 2020 Income Tax Statement of Net Liabilities. 

Schedule E PAYE liability (2020 Income Tax Return only)

You may have been entitled to warehouse some of your Income Tax liability if you were a director or employee with a material interest in your employer company. This applied to Schedule E PAYE liability for your 2020 Income Tax Return only.

You must have made a declaration on your 2020 Income Tax Statement of Net Liabilities that you were not: 

  • entitled to Income Tax warehousing as your income is more than 75% of 2019 income
  • able to claim relief under S997A TCA as your employer has warehoused their PAYE Income Tax liabilities.

Terms and conditions for the Temporary Wage Subsidy Scheme (TWSS)

It was possible to warehouse your Temporary Wage Subsidy Scheme (TWSS) and Employment Wage Subsidy Scheme (EWSS) overpayment. For this, you must have been able to show that your business is unable to repay the excess payment you received. 

Note

Failure to comply with the terms and conditions of warehousing will result in your removal from the scheme. All outstanding balances may be enforced and interest at the full statutory rate will be applied.

Next: Removal from warehouse