FAQs arising from the CIF/Revenue briefings held April – June 2010

Administration

1. Who sets limits on RCT 47's and on what basis? Can this limit be changed?

Where a subcontractor holds a valid C2 card, the principal contractor can apply to Revenue for a relevant payments card (RCT47) for that subcontractor. Upon receipt of the relevant payments card, the principal contractor is no longer required to deduct RCT at 35% from payments to the subcontractor, up to any limit shown on the payments card.

Allowing a subcontractor to be paid gross reduces the compliance burden on both the principal, the subcontractor and the Revenue Commissioners. The Revenue Commissioners have an obligation and a duty to ensure that a C2, once issued, will not be abused. Revenue fulfil this obligation by carrying out internal checks and also, where it appears appropriate for them to do so for the protection of tax revenue, by imposing a limit on the amount that a principal can pay gross to a subcontractor. This limit is notified to the principal on the payments card (RCT 47).

The limit can be determined by the size of the relevant contract and appropriate risk considerations. The limit is not a fixed monetary sum applied inflexibly in the same manner in all cases. Rather it is a flexible amount that can vary depending on the circumstances and compliance history of the subcontractor concerned and in setting a limit regard is taken, for example, of the value of payments to be made to the subcontractor under the contract concerned. The aim is to allow room for the legitimate subcontractor’s business to grow while at the same time protecting tax revenues. Where payments made to a subcontractor exceed any limit imposed on the payments card (RCT 47), RCT should be deducted from the excess.

Where a limit has been applied, the subcontractor concerned may request Revenue to alter it – by increasing it, reducing it or removing it. Where Revenue amends a limit, a new payments card (RCT 47) will be issued to the principal concerned and the subcontractor will also be informed of the amended limit.

Under the Finance Act 2010, Revenue has now been given the power to amend the limit on a payments card (RCT 47) without being requested to do so by the subcontractor. Up to then, Revenue could not, for example, increase the limit where it considered it appropriate, without a request from the subcontractor. In the exceptional circumstances where Revenue changes the limit on a payments card (RCT 47), Revenue will notify the subcontractor in writing immediately. A subcontractor can still request Revenue to change the limit on a payments card (RCT 47).

Any person aggrieved by the imposition by the Revenue Commissioners of a specified limit in relation to a relevant payments card/amended relevant payments card (RCT47), may appeal to the Appeal Commissioners against the imposition of such a limit, by giving notice in writing to the Revenue Commissioners within 30 days of the issue of the relevant payments card (RCT47) concerned. However, the limit shall remain in place pending the decision of the Appeal Commissioners.

2. Where a business is awaiting a redundancy payments rebate from the Department of Enterprise, Trade & Innovation, can this sum be offset against tax liabilities?

The Revenue Commissioners seek to facilitate, support and enable timely voluntary compliance by businesses. Where a business is awaiting a statutory redundancy rebate and it is experiencing particular difficulties in meeting its tax obligations because of a delay in receiving the repayment, then, subject to satisfactory evidence being provided of the repayment due and its quantum, Revenue will be accommodating in deferring for a reasonable period collection or enforcement action that would otherwise ensue in the event of delayed payment of tax.

Revenue has agreed with the Department of Enterprise, Trade and Innovation a form of authorisation for payment of the rebate direct to Revenue by the Department. This will facilitate the business to put in place, in a speedy fashion, the necessary arrangements to have the rebate payment made directly to Revenue. For further information, go to: Business & Self Assessment - Running a Business - Tax Payment Difficulties.

3. Is there a requirement for private individuals who make payments, say in excess of €5,000, to construction contractors to report this to Revenue?

There is no requirement on private individuals to report such payments to the Revenue Commissioners.

Businesses, however, must make a return on Form 46G of all payments that exceed €6,000 in a year, made in the course of a trade, business or activity, for services rendered in connection with the trade, business or activity. Payments made by a principal contractor registered for RCT and included on the Form RCT 35 are excluded from this requirement. Businesses, that are outside the scope of RCT, who make payments to any individual, company or any unincorporated body of persons exceeding €6,000 in a year for construction related services must make a return of these payments on Form 46G.

4. If part of a contract is subject to RCT and the other part does not appear to be, is the whole contract subject to RCT?

When certain principals make a payment in respect of a relevant contract, the payment comes within the scope of RCT. A contract under which any construction operations are carried out is a relevant contract. It is immaterial how much non-construction operations are included in the contract. If there is any element of construction operation within the contract, all payments under the contract are subject to the RCT regime.

5. Can Revenue provide clarification on what is subject to RCT and what is subject to the VAT Reverse Charge (VRC)? For example, are contracts for maintenance or repair subject to RCT? Does RCT apply to cleaning post sale?

Section 530 of the Taxes Consolidation Act sets out operations that are subject to RCT and Section 531 sets out when RCT must be applied. Section 18.2.1 in Part 18 the Tax and Duty Manuals (Income Tax, Capital Gains Tax and Corporation Tax) outlines what is a construction operation for RCT purposes. With the exception of haulage for hire, construction operations that are subject to RCT would also be subject to the VAT Reverse Charge.

Repair: Repair would generally be considered to be an operation carried out to fix, mend or restore the building/structure to its previous condition. Examples of repair include replacement of glass in a broken window, replace/fix broken tiles, mending a faulty boiler. The repair of a building or structure would be considered to be a construction operation and is therefore subject to RCT. However, the repair of removable machinery will not be subject to RCT, unless the contract included construction operations.

Where the contract is subject to RCT, then the VAT Reverse Charge generally applies.

Maintenance: Maintenance includes operations such as cleaning (internal & external) and painting (other than painting of a newly constructed building).

A maintenance contract is not subject to RCT and, as such, normal VAT rules apply.

Repair and Maintenance: If there is any element of construction operation within the contract, all payments under the contract are subject to the RCT regime. (See answer to question 4 and "Repair" and "Maintenance" notes above).

VAT Reverse Charge Rules: Despite the VAT Reverse Charge being linked to RCT, there are different rules for VAT. Due to the restrictions imposed by EU VAT Directives, Section 8(1B)(b) of the VAT Act provides that the VAT Reverse Charge kicks in, in construction cases, only in respect of ‘construction operations’. If non-construction operations are carried out under the same contract, strictly speaking, these should be invoiced as standard. The rate of VAT has no bearing on this line of demarcation.

However, for ease of administration, if the contract provides for a single consideration for the construction and non-construction elements, the subcontractor should apply VAT Reverse Charge to the full consideration. If the contract provides for separate considerations for the construction and non-construction elements, only the consideration applicable to construction operations is subject to reverse charge. Each case should be examined on its own merit.

Cleaning post sale: This is considered to be maintenance and is not subject to RCT, unless the contract includes construction operations.

The issue as to whether RCT applies to particular contracts is a question of fact in each case and depends on the wording of a contract or other arrangements made or to be made by the contractor. It also depends on who is ultimately liable to carry out the work on the contract. Questions as to whether the scheme applies to particular operations should be addressed to your local Revenue District.

For further information on the VAT Reverse Charge and construction operations please check the FAQs on the VAT Reverse Charge on the website.

6. Where a homeowner engages contractors directly to build a house, are they obliged to operate RCT on payments made to the contractors (self-builds)? What is Revenue doing about the possible shadow economy issues in this scenario?

For RCT to apply, the homeowner must be a principal for RCT purposes i.e. a person carrying on a business which includes the erection of buildings or the development of land, or the manufacture, treatment or extraction of materials for use in construction operations, or a person connected with a person (which includes any individual, company or any unincorporated body of persons) carrying on such a business.

However, if the homeowner engages a main contractor (principal) who subcontracts some of the work to other contractors (subcontractors), then the main contractor is required to operate RCT on all payments to these subcontractors.

Revenue has always maintained a significant presence in monitoring activities in the construction sector and is involved in an ongoing programme of construction related audits, compliance interventions and site visits, including one off housing, repairs, maintenance and enhancements. The Revenue Commissioners take a proactive approach to tackling non-compliance and abuses in the construction sector, often as part of Joint Investigation teams with our colleagues in the Department of Social Protection and the National Employment Rights Authority (NERA). The nature of the construction sector is that it is mainly cash based, mobile and labour intensive and these features pose compliance challenges for Revenue. While cases are mainly sourced through information in Revenue’s systems, it also uses intelligence gathered from a number of third party sources, including the general public.

7. What obligations are placed on connected parties to register as principals or otherwise apply RCT?

Background: A person connected with a company involved in a construction, land development, meat processing or forestry business must operate RCT on payments made by that person to a subcontractor in the performance of a relevant contract. This connected person rule is an anti-avoidance provision introduced in 1981 to counteract the avoidance of the operation and application of RCT through corporate restructuring.

A 'connected person' for this purpose covers both companies within a corporate group and directors/shareholders with a controlling interest in such companies acting either as individuals or as part of a partnership.

It was recognised that this provision had inadvertently brought certain parties within the scope of RCT, in a way that was never the intention of the legislation. Legislation was introduced in 2008 designed to exclude some connected persons from the RCT provisions in respect of construction operations carried out in their own premises.

Finance Act 2008 changes: Where the connection was with a meat processing or forestry company, the obligation to operate RCT in respect of construction work carried out in their own premises was removed from all persons connected with the company. Where the connection was with a company involved in construction or land development activities, the obligation was only removed from connected companies. In this context, it is important to note that the obligation to operate RCT was only removed in respect of work carried out in the connected company's own premises. Where such connected companies were involved in letting out property, they were obliged to continue to operate RCT in respect of construction operations carried out in such property.

As the 2008 Finance Act only removed the RCT obligation from companies where the connection was with a construction company, directors/shareholders with a controlling interest in construction companies were obliged to continue to operate RCT in respect of construction operations carried out in a private capacity and partnerships involving such directors/shareholders were also obliged to operate RCT in respect of all construction operations carried out on their behalf.

New Treatment:

Companies, Shareholders & Directors
Revenue outlined in Tax Briefing 71 (April 2009) that it was prepared to extend the modification of the RCT legislation to apply in certain limited circumstances to construction work carried out in premises that have been let out -
1. by persons connected with companies in the meat processing or forestry businesses, and
2. by companies connected with companies in construction and land development businesses.
The type of work which will qualify for this treatment (i.e. the obligation to operate RCT will not apply) is minor repair or improvement work to rented property where the total value of contracts awarded per property in any tax year in respect of such repairs or improvements does not exceed €20,000 (incl. VAT).
The new approach outlined above will also apply in respect of minor repairs or improvements carried out in a private capacity on their own home (including outhouses and pleasure gardens), or private letting's, or other incidental private work (e.g. erection of a memorial monument) by a director/shareholder with a controlling interest in a construction company.
Sole Traders & Partnerships
Building contractors operating as sole traders or in partnership are reminded of their obligations regarding the operation of RCT. A builder who is a sole trader or in partnership is a principal under Section 531(1)(b)(i) TCA 1997 as s/he is 'a person carrying on a business which includes the erection of buildings'. S/he must operate RCT in respect of all payments made to subcontractors who carry out construction operations for him/her, including construction operations carried out in a private capacity (i.e. non-business related construction activities).
However, the new approach outlined in Paragraph 1 above (i.e. minor repairs or improvements where the total value of contracts in respect of such work does not exceed €20,000 (incl. VAT) per property in a tax year) will also apply in the case of a sole trader or partnership in respect of such work carried out in a private capacity on their own home (including outhouses and pleasure gardens) or private letting's, or in respect of other incidental private work (e.g. erection of a memorial monument).
The above is a summary of the modification. Interested parties should note that full details of the modification are contained in Tax Briefing 71.
Where companies or individuals have a doubt as to whether RCT applies in any particular circumstances or to any particular works, they should contact their local Revenue District for advice.

8. Where, exceptionally, a principal fails to operate RCT on payments to C2 holding subcontractors where they do not hold a payments card (RCT 47), Revenue charges a fixed penalty of €3,000. In circumstances where the tax that should have been deducted is less than €3,000, what options are available?

In completing the Form RCT 35, principals or their agents may have come across instances where gross payments were made to a subcontractor who had a valid C2, but the principal was not in possession of the payments card (RCT 47) for that subcontractor. Where the error of this nature is exceptional, and a qualifying disclosure is made to Revenue within one month of the filing date, Revenue will not seek to impose the normal tax, interest or tax-geared penalties. Instead, a fixed penalty (currently €3,000) will apply to each instance of the failure to deduct the correct tax.

Full details were outlined in eBrief 10 of 2007.

Various treatments were also outlined in the eBrief, which may be more beneficial. These treatments only apply where the subcontractor held a valid C2.

No Loss of Revenue:
Where it can be shown to the satisfaction of Revenue that there was "no loss of RCT", the penalty for non-operation of RCT will be mitigated to the lesser of 3% of the RCT underpaid or €60,000, whichever is the lesser, provided there has not been a general failure by the taxpayer to operate RCT. The relevant RCT and interest is, of course, also payable.
No Loss of Revenue (Group Cases):
Interest and penalties are not generally pursued in respect of RCT on intra-group transactions involving "no loss of RCT". This is subject to the requirement that both group companies involved had been otherwise tax compliant at the time the relevant transaction(s) took place. The RCT is, of course, payable.

The Code of Practice for Revenue Auditors allows taxpayers to "self-correct" returns without penalty subject to certain conditions. For RCT, the self-correction must take place within twelve months of the due date for filing the annual return. In this instance, the relevant RCT and interest is payable.

Under the Code of Practice for Revenue Auditors, a penalty is not to be pursued if the aggregate amount of tax in respect of which penalties are computed is less than €3,000 and the default is exclusively in the insufficient care category of tax default. The category of insufficient care is intended to cater for defaults of a minor nature which are discovered during many Revenue audits, for example computational errors and inadequate adjustments for personal expenditure in the profit and loss account. Full details are in the Code of Practice for Auditors. Again, the relevant RCT and interest is payable. The treatment outlined in the Code can apply to circumstances where the subcontractor is not a valid C2 holder.

9. Am I required to store paper documents for the required time or can these records be stored electronically?

Records must be kept for six years unless Revenue advises otherwise. The obligation to keep proper records rests with the taxpayer.

Businesses are allowed to keep records electronically, without specific Revenue approval, provided that they are kept in accordance with guidelines published by the Revenue Commissioners. These guidelines are available in Revenue’s Tax Briefing Issue 46 (PDF, 810KB) - pages 24-25 (December 2001) and in Section 38.3.14 of Part 38 of the Tax and Duty Manuals (Income Tax, Capital Gains Tax and Corporation Tax).

Form RCT 1:

Note: FAQ's on RCT 1 procedures are also available on the website.

1. Is there a need to complete and retain an RCT1 for each contract that a subcontractor is engaged in, even where it is clear that the subcontractor is engaged in the same work in each instance?

If the subcontractor is engaged by the same principal on a number of contracts to perform the same work under the same contractual terms (and they apply to each contract entered into between the parties), then it would be considered to be an ongoing contract - this would still be the case even if the contracts are carried out on a number of different sites, the jobs don't succeed each other immediately (i.e. where there are breaks in the work) or where some payments might be withheld (pending completion of the work to an agreed standard).

Where there is an ongoing contract, only one RCT 1 needs to be completed between the parties. This Form satisfies the requirements for all subsequent contracts, once the above criteria are satisfied. This RCT 1 needs to be retained by the principal for 6 years.

However, even if it appears to be an ongoing contract (same work being performed on each contract) a new form will need to be completed for the contract, if:

The subcontractor has to compete for new work; or
The contractual relationship between the parties has changed e.g. the principal sets up a new entity (e.g. limited company) for each site; or
The contractual terms have changed significantly e.g. the payment arrangements have changed from fixed price to piece work; or
No payments were made in the preceding year (e.g. no record of the subcontractor on the Form RCT 35).

Audit/Revenue Interventions

1. What tax obligations has a non-resident contractor? If a non-resident contractor leaves the State will Revenue pursue the non-resident for tax due?

Briefly, depending on circumstances, non-resident contractors engaged on construction contracts in the State could have liabilities for the following taxes:

VAT
Due to the introduction of the VAT Reverse Charge, it is mainly principal contractors who will have a liability for VAT.
RCT
Once the work is being carried out in the State, RCT applies irrespective of whether the principal contractor or the subcontractor or both are resident outside the State.
Employer Payroll Taxes and Levies
With effect from 1st January 2006, all employers including non-resident employers must register for PAYE as an employer and operate PAYE/PRSI in respect of income attributable to the performance of the duties of the foreign employment in the State. Exemptions apply in certain cases.
Income Tax/Corporation Tax
As a general rule, all persons earning income in the Republic of Ireland are taxable in the Republic of Ireland. However, there are provisions in Double Taxation Agreements that confine this to taxpayers who have a 'permanent establishment' in the Republic of Ireland, if these taxpayers are taxable abroad.

The tax obligations of non-resident contractors (PDF, 135KB)are outlined in more detail on the Revenue website.

If a non-resident contractor leaves the State without fully complying with his/her tax obligations, Revenue will pursue the contractor by contacting the Revenue authorities in their "home" jurisdiction. Through agreements that are in place, the appropriate jurisdiction will pursue the taxpayer for the tax debt that has been established in this State.

For example, if the contractor is from Northern Ireland, Revenue is in a position, under mutual assistance agreements, to exchange information on the taxpayer with HM Revenue & Customs (HMRC) and thereby pursue the tax debt due.

2. From an audit perspective, are non-resident companies treated differently to Irish companies?

A central Non-Resident Unit in Dublin deals with non-resident contractors, including those based in Northern Ireland. This unit, which was set up in 2006, has built up expertise in the compliance issues posed by non-resident contractors and how to address these issues.

In relation to Revenue interventions, cases are selected for audit or other intervention (e.g. site visit, assurance check) based primarily on their level of risk. This applies equally to resident and non-resident taxpayers. Risk is determined using Revenue’s Risk Evaluation and Analysis Programme (REAP) and local intelligence. REAP is a sophisticated case selection system that enables Revenue to focus on high-risk customers and to minimise interactions with compliant customers.

3. What information can be shared between Revenue, the Department of Social Protection and the National Employment Rights Authority?

Revenue actively works with the Department of Social Protection (DSP) and the National Employment Rights Authority (NERA) to combat tax evasion and social welfare fraud and to monitor employment rights compliance through Joint Investigation Units (JIUs). Apart from the large annual central data exchanges, information is shared on individual cases between the three areas. The sharing of information between Revenue, DSP and NERA is governed by legislation.

Data and information are exchanged daily, weekly and annually at a number of levels – for example the regular bulk data exchange of employment related information and case by case information sharing between officers working in the Joint Investigation Units. Revenue can also share information contained on Forms RCT 1.

JIUs have been operating between DSP and Revenue for many years. Their role is to address areas where evidence suggests non-compliance exists. Under Towards 2016 – The Ten Year Framework for Social Partnership – it was agreed that the JIUs would be strengthened and expanded. Revenue more than doubled its numbers. Since mid 2007, NERA officers have been working with both Revenue and DSP JIUs. Information and intelligence has been shared and joint visits to construction sites and other businesses have been carried out.

4. Does Revenue receive vexatious "Good Citizens Reports" (GCR) and, if so, how many?

No record is kept of the number of vexatious GCRs that are submitted to Revenue.

When a GCR is received, it is sent to the appropriate district where a suitably experienced officer carefully evaluates it before a decision is made on what action, if any, is to be taken. Having regard to the provisions of the Revenue Customer Service Charter, the content of the information provided is examined initially to assess its accuracy in the light of the known facts, before any investigation is carried out into the tax affairs or activities of the individual /company who is the subject of the report.

ROS:

1. Is there a limit on the number of subcontractors that can be entered on the RCT 35 via the Revenue Online Service (ROS)?

A maximum of 30 subcontractors can be entered while on-line. However, the off-line application will allow you to enter up to 1,000 subcontractors.

2. Will Revenue be providing a facility to auto-populate the ROS Form RCT 35? Does Revenue have any plans for a computerized payments card (Form RCT 47)?

In Revenue, we constantly review our systems to meet the needs of our customers and improve the user experience. Ongoing enhancements are developed in response to defined and prioritised requirements. While these facilities are not available at present, the possibility of providing them will be considered as part of our ongoing review of the RCT system. However, given the current budgetary constraints, it is not possible to be definitive as to when they might be introduced.

3. Are there any plans for RCT enhancements to ROS?

There are no immediate plans for enhancements to the RCT services in ROS. However, Revenue has already delivered significant information and communications technology (ICT) based solutions to simplify systems, cut costs and speed up the delivery of services. Making it as easy as possible for customers to do business with Revenue is essential to maximise voluntary compliance. Revenue helps minimise compliance costs, which in turn contributes to the competitiveness of the economy.

Notwithstanding other potential demands on its resources, Revenue is committed to providing the resources necessary to ensure that ROS becomes a central part of its filing, payment and information services over the next number of years.

ROS is committed to full and open consultation with all stakeholders on this. Revenue had detailed discussions with tax practitioners and professionals’ representative bodies initially and continues to maintain an ongoing dialogue with practitioners’ representatives in advising them of developments, consulting with them and seeking their assistance in addressing areas of concern to their members and in promoting ROS

For more information contact the ROS Helpdesk at 1890 201 106 or email roshelp@revenue.ie.

Other:

1. What is Revenue's position on schemes such as the "rent to buy" and "care-taking arrangements" and what are the tax implications of these?

These schemes have various names - 'Rent to Buy', 'Homemaker', etc. In general, the agreement is structured using an initial period of renting with an option to purchase at the end of the letting period.

The letting of residential property is exempt from VAT. The landlord's option to tax cannot apply to the letting of residential property.

Some of these schemes have advertised the period of occupation as a 'caretaker' agreement. Revenue does not accept that the agreement which allows the prospective purchaser to exclusively occupy the house for a defined period is anything other than a letting agreement for VAT purposes.

If there is an up front payment, unless refundable at the end of the letting period, it is treated as a payment in respect of the granting of an option to purchase the property. This option payment is not a deposit for VAT purposes and is subject to the same rate as the supply of the property – subject to the reduced rate of VAT.

Any monthly payments made by the prospective purchaser represent consideration for the letting of the property and, in some cases, consideration relating to the option to buy the property. Any amount payable per month up to the market rent of the property (the rent that a similar house in the area would fetch on the open market) is treated as consideration for the exempt letting. Any amount in excess of this market rent is treated as consideration for the option to purchase the property.

As there are many variations of these schemes the exact treatment of the arrangements for VAT purposes can only be established by the facts of each individual case. However, interested parties are advised to check out the information on "Rent to Buy" schemes that is available on the Revenue website.

2. If a house that was built to be sold is now being let, what are the VAT clawback implications?

The letting of residential property is exempt from VAT. The landlord's option to tax cannot apply to the letting of residential property.

Some schemes have advertised the period of occupation as a 'caretaker' agreement. Revenue does not accept that the agreement which allows the prospective purchaser to exclusively occupy the house for a defined period is anything other than a letting agreement for VAT purposes.

Adjustments of deductibility for exempt letting

As the property is being used for an exempt purpose during the period when it is rented, the lessor is obliged to make an adjustment where he/she has claimed VAT deductibility in relation to the acquisition or development of the property.

Further information on Rent to Buy schemes and the clawback under the Capital Goods Scheme are available on the website.

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FAQs arising from the CIF/Revenue briefings held April – June 2010

Administration:

Form RCT 1

Audit/Revenue Interventions

ROS

Other

Administration

1. Who sets limits on RCT 47's and on what basis? Can this limit be changed?

2. Where a business is awaiting a redundancy payments rebate from the Department of Enterprise, Trade & Innovation, can this sum be offset against tax liabilities?

3. Is there a requirement for private individuals who make payments, say in excess of €5,000, to construction contractors to report this to Revenue?

4. If part of a contract is subject to RCT and the other part does not appear to be, is the whole contract subject to RCT?

5. Can Revenue provide clarification on what is subject to RCT and what is subject to the VAT Reverse Charge (VRC)? For example, are contracts for maintenance or repair subject to RCT? Does RCT apply to cleaning post sale?

6. Where a homeowner engages contractors directly to build a house, are they obliged to operate RCT on payments made to the contractors (self-builds)? What is Revenue doing about the possible shadow economy issues in this scenario?

7. What obligations are placed on connected parties to register as principals or otherwise apply RCT?

9. Am I required to store paper documents for the required time or can these records be stored electronically?

Form RCT 1:

1. Is there a need to complete and retain an RCT1 for each contract that a subcontractor is engaged in, even where it is clear that the subcontractor is engaged in the same work in each instance?

Audit/Revenue Interventions

1. What tax obligations has a non-resident contractor? If a non-resident contractor leaves the State will Revenue pursue the non-resident for tax due?

2. From an audit perspective, are non-resident companies treated differently to Irish companies?

3. What information can be shared between Revenue, the Department of Social Protection and the National Employment Rights Authority?

4. Does Revenue receive vexatious "Good Citizens Reports" (GCR) and, if so, how many?

ROS:

1. Is there a limit on the number of subcontractors that can be entered on the RCT 35 via the Revenue Online Service (ROS)?

2. Will Revenue be providing a facility to auto-populate the ROS Form RCT 35? Does Revenue have any plans for a computerized payments card (Form RCT 47)?

3. Are there any plans for RCT enhancements to ROS?

Other:

1. What is Revenue's position on schemes such as the "rent to buy" and "care-taking arrangements" and what are the tax implications of these?

2. If a house that was built to be sold is now being let, what are the VAT clawback implications?