Emergency Measures in the Public Interest (Covid-19) Act 2020 section 28C

Covid-19: special warehousing and interest (relevant tax due under section 28(9))

Section 28C allows employers to "warehouse" (defer payment of) excess temporary wage subsidy scheme (TWSS) amounts that must be refunded to Revenue, and sets out the interest rules that apply during and after the deferral period.

  • Employers affected by Covid-19 who remain tax-compliant can defer repayment of excess TWSS amounts, with no interest during Period 1 and Period 2, and must engage with the Collector-General to agree a repayment plan
  • Where the employer engaged with Revenue before 1 May 2024 and entered into a payment agreement, and continues to comply with all tax obligations and the terms of that agreement, no interest is charged across all three periods
  • If an employer fails to comply with tax obligations or does not enter into an agreement, simple interest at 0.0219% per day applies on the outstanding amount from the date of non-compliance or from 1 May 2024, as the case may be
  • Compliant employers can still obtain tax clearance certificates and Revenue will not pursue enforcement of the warehoused debt during the deferral period

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