Real-time Reporting: six months on

28 June, 2019

PAYE Real-time Reporting (RTR) was introduced in Ireland on 1 January, 2019. In this update, we provide insights into the areas Revenue is currently focusing on, as well as how employees interact with RTR.

Employee visibility of employer-filed PAYE details

With effect from mid-May 2019, employees can now view certain PAYE data which have been reported to Revenue by their employers. The information relating to an individual's pay received during each pay period, as well as tax and PRSI deductions, can be viewed by PAYE taxpayers on Revenue's myAccount platform. Here, employees will also be able to access their End of Year Statement, which will replace the P60 from 2019.

If you haven't already done so, now is the ideal time to communicate with your employees about the changes which RTR brings and the impact for them. Proactively preparing and implementing a communications strategy can cut down on reactive time spent dealing with repetitive queries.

A team meeting in a bright office surrounded by windows.

Common employer mistakes in filing Revenue payroll submissions

Revenue has published a list of common errors in payroll submissions which have been made by employers since 1 January 2019 go-live date.

These include:

  • Employers mistakenly sending the payroll data to Revenue more than once; this can incorrectly inflate the declared income and the corresponding liability, and raises the risk of unnecessary Revenue interventions.
  • Employers incorrectly creating duplicate employments for the same employee, resulting in an overstatement of a liability owing to Revenue (due to the incorrect allocation of tax credits and bands).
  • Payroll submissions failing the validation process. This can result in invalid submissions not being included in the employer's Monthly Statement thereby incorrectly reducing the liability (the Monthly Statement is issued by Revenue early in the month following the payroll month, and must be corrected before it becomes a statutory return on the 14th day of that month).
  • Employers ceasing employment in error by incorrectly including cessation dates for employees in payroll submissions.
  • Employers failing to apply the most up to date Revenue Payroll Notification 'RPN' when running payroll (in this regard, employers should note that revised RPNs may issue later in the month and Revenue expects these to be applied even where the revised RPN has issued subsequent to the company's internal "payroll cut-off" date), where the revised RPN issues before the pay date.
  • Employees being taxed on the emergency tax basis where an RPN is available but not applied.
  • No USC deducted where the employee is not USC exempt. USC deducted where the employee is USC exempt.
  • Employers paying their tax liability twice in error, e.g. by setting up both a ROS Debit Instruction and Variable Direct Debit for the same payment period.

Employers should strive to ensure that errors are identified and resolved before the relevant submission is uploaded to Revenue, but in any event any issues must be identified and corrected before the statement becomes the statutory return on the 14th day of the month following the payroll month.

Data quality

Revenue is monitoring all data included in submissions received in real time and is actively engaging with employers where Revenue believes submissions are inaccurate or incomplete. Revenue has confirmed that for a submission to be complete all data points, including information points, which do not affect the tax liability must be accurate and complete for all employees. Revenue has created a specific team of resources to analyse the quality of payroll submissions: this team is expected to conduct site visits at employers' premises as part of its remit.

This underlines the need for employers to ensure that all internal and external stakeholders to payroll are aware that complete, accurate and timely data provision to payroll is key to successful payroll compliance under RTR.

Penalties

In a recent eBrief, Revenue stated that it will continue to assist employers who are experiencing genuine difficulty in complying with the new PAYE requirements. However, if employers fail to engage with Revenue or have persistent breaches of the PAYE regulations, they are liable to be issued with a €4,000 penalty per offence.

As such, employers should be aware that it is crucial for them to use their best efforts to ensure that their payroll reporting is as accurate as possible in real time, otherwise penalties may be applied. Particularly, as the year progresses, employers are expected to become more familiar with their obligations under Real-time Reporting.

If you have any queries in relation to data quality, employee engagement or any other aspect of your payroll under RTR, don't hesitate to reach out to the PwC Real-time Reporting team or your regular PwC contact.

Contact us

Doone O'Doherty

Partner, PwC Ireland (Republic of)

Tel: +353 1 792 6593

Jessica Webbley-O'Gorman

Senior Manager, PwC Ireland (Republic of)

Tel: +353 1 792 6518

Emily Bourke

Senior Manager, PwC Ireland (Republic of)

Tel: +353 1 792 6796

Follow PwC Ireland