Guidance on the Level 1 Compliance Programme – Debt Warehouse Scheme

Revenue eBrief No. 177/22

Guidance on the Level 1 Compliance Programme – Debt Warehouse Scheme

Revenue has published a new Tax and Duty Manual – Guidance on the Level 1 Compliance Programme – Debt Warehouse

In September 2022, Revenue issued a Level 1 Compliance Intervention notification offering taxpayers an opportunity to self-review returns eligible for debt warehousing and, if additional undisclosed relevant liabilities arise, these can benefit from the provisions of the DWS.  By making an Unprompted Qualifying Disclosure in relation to previously undisclosed Period 1 liabilities on or before 31 January 2023, the taxpayer has an opportunity to have those additional liabilities warehoused under the terms of the DWS.

A taxpayer who makes an Unprompted Qualifying Disclosure also receives the normal benefits of mitigation of the tax-geared penalty (in cases where such a penalty applies), non-publication of the tax settlement and non-prosecution.

Detailed information regarding the compliance programme and the opportunity to disclose additional liabilities is outlined in this Tax and Duty Manual.

You should receive a letter by post outlining if this applies to you and what to do if you are or are not required to make a disclosure to the Revenue Commissioners.


1.2 Debt Warehousing Scheme (DWS)
The Debt Warehousing Scheme (DWS) allows for the deferral of the payment of VAT, Employer PAYE, certain self-assessed income tax labilities, and also subsidy overpayments under the Temporary Wage Subsidy Scheme (TWSS) and the Employment Wage Subsidy Scheme (EWSS).

As part of the response to the Covid-19 crisis, the DWS was automatically made available to customers in Business and Personal Divisions and available, on application, to medium-sized enterprises and Large Corporate taxpayers, subject to specific criteria.

Under the provisions of the legislation, a taxpayer who avails of the DWS must meet their obligations under the Tax Acts. Taxpayers must have filed all relevant returns on time and accounted for all relevant liabilities in order to qualify for debt warehousing. Current taxes must also be filed and paid as they fall due. For detailed guidance on the DWS please see Information Booklet on Warehousing
of Tax Debts associated with COVID-19.