Form 46G
Return of Third Party Information
As you may know the Revenue Commissioners recently brought Phase 3 of their electronic filing initiative into effect. One of the results of this is that companies with year ends falling after 31 December 2010 will have to prepare and submit an electronic 46G. This modernisation was essential for the smooth operation of the Form 46G. The old paper format was cumbersome for both taxpayers and the Revenue Commissioners.
It is necessary to include the following payments on the Form 46G:
- payments made, in the course of the trade, business or activity for services rendered in connection with the trade, business or activity including payments for services provided in connection with the formation, acquisition, development and disposal of the trade, business or activity (including such payments made on behalf of others)
- particulars of payment made in a form other than money
- payments for copyright.
The following payments can be excluded from the form:
- payments made to any person (company, individual or other body) where the total amount does not exceed €6,000
- payments from which income tax has been deducted
- payments in which the value of goods provided as part of the service exceeds two-thirds of the total charge
- payments made to Government Departments, Local Health Offices, VEC’s, Local Authorities and Semi State Bodies
- payments made to non residents
- payments made by a principal, registered for RCT, where the payments are returned on Form RCT35.
The services in respect of which returns of payments are required are:
Accountancy (including auditing, taxation and company secretarial), actuarial, advertising/promotion, agricultural/general contracting, architectural (including draughtpersons), auctioneering, bookkeeping, building repair/maintenance, catering, cleaning, commissions, computer (including software), consultancy, courier/delivery, dentistry, diving, electrical, engineering, entertainment (musicians, singers etc.) equipment/plant hire, exhibitions, haulage, journalism, legal, medical, merchandising, model agency, nursing, photographic, plumbing, printing, promotion, public relations, secretarial, security and investigation, surveying, training/education, translation/interpreting, transport, vehicle repair / maintenance, veterinary.
As you will note almost all of the services received by companies should be returned on the 46G!
It may be useful to contact your accounts package provider. Most of the major software companies can provide a link to some of the functionality of ROS. It would save considerable time and effort if a supplier was identified as providing services which should be returned on the 46G at initial engagement and steps could be taken to capture the payment.
The move to electronic filing is a pre-cursor to the eventual introduction of iXBRL filings here in Ireland. Currently, in the UK, companies must file a set of accounts with the Revenue authorities. Each figure in these accounts must be electronically tagged using a piece of software called iXBRL. The tag will give information about the composition of the figure to the Revenue authorities. We understand that the Revenue Commissioners are monitoring the introduction and operation of this system in the UK closely with a view to its implementation here in Ireland. When this is implemented it is possible that the Revenue Commissioners will be able to track the payments in the accounts which should be included in the Form 46G. With this in mind it is important that your company ensures that sound procedures for identifying 46G expenses are implemented from an early stage.
The Form 46G must be completed using the Revenue Online System (ROS) offline application. The ROS offline application is available for download in the ROS section of the Revenue Commissioners website www.revenue.ie and is reasonably straightforward to use. Once the offline program has been downloaded the Form 46G can be downloaded from the “download” section of the application.
Completing the online 46G is the same as completing the paper form in terms of content. Once completed, you can upload the return directly to the Revenue Commissioners via the ROS website. Alternatively, and more preferably, you can forward the completed return to us via email at tax@bakertillyrg.ie (in the appropriate file format) and we will upload the return along with the corporation tax return.
We can also complete the Form 46G on your behalf for a time based fee, and this work will usually be carried out in the main by a trainee. If you would like us to do this, please complete this spreadsheet (available here). A separate sheet should be completed for each entry. If you want to copy a sheet simply right click the sheet tab and click create copy. Once completed please e-mail the spreadsheet to us and we will populate the form on your behalf.
