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Corporate Tax Deadlines
 7
December 2005
Budget Day 2006. Anti-avoidance measures (if
any) may take effect from this date.
14
December 2005
Dividend withholding tax return filing and payment
date (for distributions made in November 2005).
21
December 2005
Due date for payment of preliminary tax for companies
with a financial year ended
31 January 2006 and due date for payment of 2nd instalment
of preliminary corporation tax for companies with a
financial year ended 30 June 2005.
21
December 2005
Last date for filing corporation tax return CT1
for companies with a financial year ending on 31 March
2005 with the Collector General’s Office.
Due date for balancing payments for the same period.
31
December 2005
Last date for filing third party payments return
46G for companies with a financial year ending on 31
March 2005.
31
December 2005
Latest date for payment of dividends for the
period ended 30 June 2004 to avoid Sections 440 and
441 TCA97 surcharges on investment/rental/professional
services income arising in that period (close companies
only).
31
December 2005
Certificates for IFSC and Shannon companies are
due to expire on 31 December 2005. All trading income
arising thereafter, will be taxable at the standard
rate of tax at 12.5%. Some of the implications arising
from the expiration of the IFSC certificates are outlined
below.
There are certain restrictions imposed by IFSC certificates
which will no longer apply once the certificates have
expired. Transactions with connected persons will no
longer be required to be conducted at arms length. There
will no longer be any restriction on the types of activities
that a company may engage in, which will facilitate
expansion into other types of business.
Apart from the reduced corporation tax rate, the main
advantage available to IFSC companies is that they can
do business with foreign companies irrespective of where
those companies were resident, with minimal withholding
tax or interest recharacterisation issues. Non-IFSC
certified companies conducting business with non-EU
or non-treaty partner countries are exposed to recharacterisation
and withholding tax issues. Companies losing their IFSC
certificates will need to address these issues.
Currently, it is possible to claim 100% accelerated
capital allowances on certain assets used for the purposes
of an IFSC or Shannon trade which qualifies for the
10% rate of tax. These accelerated allowances will cease
to be available post 31 December 2005 when the IFSC
and Shannon regimes expire.
31
December 2005
Contributions made by employers to approved occupational
pension schemes are tax deductible on a payment basis.
Companies with 31 December year ends should review their
position to ensure minimal pension accruals/provisions
at the year end.
Charges on income (e.g., patent royalties and certain
interest) are also deductible on a paid basis. Trade
interest accrued on a liability between connected persons
may also need to be paid by 31 December 2005 to avoid
a denial of the tax deduction for that period.
31
December 2005
A two year time limit applies to many corporation tax
group relief and loss relief claims. Potential claims
for the period ending 31 December 2003 may need to be
considered prior to 31 December 2005. A similar time
limit applies to certain income tax claims.
31
December 2005
The time limit for claiming a repayment of tax
is 4 years. A claim for repayment of tax for the tax
year 2001 must be lodged with the Revenue by 31 December
2005.
31
December 2005
Every ‘paying agent’ is required
to make an annual return providing details of interest
payments falling within the ambit of the EU Savings
Directive. The first such return covers the period 1
July 2005 to 31 December 2005 and is required to be
submitted by 31 March 2006.
1
January 2006
On 12 April 2005 a new double taxation agreement
between Ireland and Canada entered into force. The revised
agreement will apply from 1 January 2006.
The new treaty will cover transactions subjected to
CGT for the first time. In addition, new articles dealing
with dividends, interest and royalties generally provide
for lower withholding taxes than apply at present. On
a less positive note certain tax exemptions will be
removed and the tax credit available on Canadian dividends
paid to Irish individuals will be substantially reduced.
A tax treaty with Chile was signed in 2005. If ratification
procedures are completed in 2005, this treaty will also
be in force from 1 January 2006.
14
January 2006
Dividend withholding tax return filing and payment
date (for distributions made in December 2005).
21
January 2006
Due date for payment of preliminary tax for companies
with a financial year ended 28 February 2006 and due
date for payment of 2nd instalment of preliminary corporation
tax for companies with a financial year ended 31 July
2005.
21
January 2006 Last date for filing corporation
tax return CT1 for companies with a financial year ending
on 30 April 2005.
Due date for any balancing payment in respect of the
same accounting period.
31
January 2006
Last date for filing third party payments return 46G
for companies with a financial year ending on 30 April
2005.
31
January 2006
Latest date for payment of dividends for the
period ended 31 July 2004 to avoid Sections 440 and
441 TCA97 surcharges on investment/rental/professional
services income arising in that period (close companies
only).
31
January 2006
Transitional measures were introduced in Finance
Act 2005 to provide for companies' first-time adoption
of International Financial Reporting Standards (IFRS)
or equivalent Irish GAAP.
One of the transitional measures provided for special
rules re the first instalment of preliminary corporation
tax for the first accounting period for which relevant
standards are adopted. For example, for a company with
a 31 December 2005 year end, unrealised gains and losses
on financial assets and liabilities arising in the period
1 November 2005 to 31 December 2005 may be disregarded
in ascertaining if the payment represents 72% of the
tax due on 21 November 2005. However, any shortfall
in the payment to bring it up to 72% must be paid over
to Revenue by 31 January 2006. All other preliminary
tax obligations must be met by 21 November 2005.
31
January 2006
If a company with a 31 December year end realises chargeable
gains in the period 22 November 2005 to 31 December
2005, i.e., gains arising after the due date for the
first instalment of preliminary tax, a ‘top-up’
facility is available. No interest will be charged if
the ‘top-up’ payment is made by 31 January
2006. The aggregate of the payments, i.e., the first
instalment of preliminary tax plus the ‘top-up’
payment, must be at least 72% of the final tax liability
for that period. |
