Author

Mary Healy is senior representations manager, and Lorraine Sheegar is tax manager, at the Irish Tax Institute

At the beginning of June, the government launched its economic recovery plan 2021, setting out a new phase of support for the next stage of the economic recovery after the Covid-19 pandemic and its aim of exceeding the pre-coronavirus employment levels of 2.5 million people in work by 2024. It also released its national recovery and resilience plan, outlining how Ireland intends to utilise the initial allocation of grants of approximately €915m that it will receive from the EU’s recovery and resilience facility.

The Finance (Covid-19 and Miscellaneous Provisions) Bill 2021 incorporates the legislative amendments to existing support and the new measures announced in the economic recovery plan 2021. Its publication on 22 June preceded the decision to defer the restart of indoor dining, which had been scheduled for 5 July, due to concerns about the delta variant of coronavirus. Further changes to the measures may be required as the situation evolves.

EWSS and CRSS

Currently, the bill extends the expiry date of the employment wage subsidy scheme (EWSS) from 30 June until 31 December 2021. The current payment rates will be maintained for July, August and September (Q3). The reference period for assessing scheme eligibility will be expanded from the current six months to a full 12-month period. The government has indicated that employers availing of the scheme in the fourth quarter may have to contribute to employees’ pay. A decision is expected to be made in August, at the earliest.

The bill also extends the Covid restrictions support scheme (CRSS) from 30 June until 31 December 2021 and will provide additional support to businesses upon reopening. Enhanced ‘restart week’ payments (double or triple-week CRSS amounts depending on the reopening date) have been provided for in the bill. Weekly caps apply to these payments.

A new business resumption support scheme (BRSS) will be implemented in September for businesses with reduced turnover because of public health restrictions

Following the announcement on 29 June that the reopening of indoor dining will not proceed as planned, it has been confirmed that businesses that remain closed or significantly restricted under public health measures may claim CRSS payments for a further two weeks. This will allow such businesses to obtain a double-week payment from the week commencing 5 July (subject to the statutory cap of €5,000 per week). All businesses benefitting from this additional support may also qualify for the enhanced restart payment once they do reopen.

Revenue’s CRSS guidelines have been updated accordingly and provide guidance to businesses that have already claimed a triple-week restart payment in anticipation of a reopening they are not now allowed to proceed with.

Further measures

The debt warehousing scheme has been extended to the end of 2021. This means that taxpayers who qualify for debt warehousing for their Covid-related tax debts will not have to start repaying them until 1 January 2023. Interest will then be charged at a reduced rate of 3% per annum. The warehouse has also been extended to include repayment of EWSS.

A new business resumption support scheme (BRSS) will be implemented in September for businesses with reduced turnover because of public health restrictions. BRSS is available to affected self-employed individuals and companies who carry on a trade, the profits of which are chargeable to tax under case I of schedule D. It is also available to persons who carry on a trade in partnership, and any trading activity carried on by charities and sporting bodies.

BRSS will operate in similar way to CRSS. For example, it uses ‘average weekly turnover’ to calculate the payment to the business, and the requirement to hold tax clearance and claims will be made through ROS. Revenue guidance on the new scheme is expected to be published in due course.

The reduced 9% VAT rate for the tourism sector has also been extended from 31 December 2021 to 31 August 2022.

PUP

As part of the economic recovery plan 2021, the Covid-19 pandemic unemployment payment (PUP) was extended in its current form for existing claimants from 30 June to 7 September 2021. The weekly rates of PUP support will then be reduced on a phased basis, as outlined on the Department of Social Protection website.

Covid-PUP was due to close to new applicants from 1 July 2021, but the application deadline has been extended up to and including 7 July as a result of the postponement of the reopening of indoor dining. The scheme will be kept under review. Covid-PUP will cease for full-time students from the start of the 2021/22 academic year, with the last payment to students on 7 September.

The most significant exemption from the stamp duty charge is the multiple purchase of apartments

Stamp duty

Following widespread concerns about institutional funds purchasing new housing estates and the impact of this on first-time buyers, the Dáil passed a financial resolution in May imposing stamp duty of 10% on the multiple purchase of 10 or more residential units.

This measure has now been incorporated in the Finance (Covid-19 and Miscellaneous Provisions) Bill 2021. The 10% rate of stamp duty will also apply where a person acquires 10 or more units on a cumulative basis over a 12-month period. Once triggered, the 10% rate will apply to all residential units acquired in that 12-month period, including the first nine purchases.

The new provisions include measures that apply to shares or units of companies, Irish real estate funds (IREFs) and partnerships that derive their value, directly or indirectly, from a residential unit. There is a three-month transition period for the execution of contracts entered into but not completed prior to 20 May 2021.

Multiple purchases by local authorities, approved housing bodies and the Housing Agency are outside the scope of the higher stamp duty charge. The bill also sets out measures to exempt any residential units leased to local authorities (or acquired and immediately leased to a housing authority) for certain social housing purposes.

The most significant exemption from the stamp duty charge is the multiple purchase of apartments. The Department of Finance has stated that this is because apartment developments face marked viability challenges. Any additional cost burden ‘would have significant negative consequences for supply, and consequently impact on our future housing model, in particular for urban living’.

Disclaimer: while every effort has been made to ensure the accuracy of this information, the Irish Tax Institute does not accept any responsibility for loss or damage occasioned by any person acting, or refraining from acting, as a result of this material.

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