VAT-Reverse Charge

Overview
Where a board receives construction services, other than haulage for hire, it must account for VAT on such services to Revenue. The method of accounting for VAT in such cases is known as reverse charge.

The charge the sub-contractor makes to a principal contractor i.e. the school, does not include VAT. Instead the school calculates the VAT on the amount charged by the sub-contractor and pays the VAT directly to the Revenue Commissioners through the VAT return. The invoice received from the subcontractor should contain the following statement “VAT on this supply to be accounted for by the Principal Contractor”.

Registering for VAT
From March 2021 a school is VAT registered solely for the purposes of Relevant Contract Tax (RCT) on construction services supplied by a sub-contractor. A school is only accountable for the Reverse Charge VAT on services supplied by a sub-contractor. This applies to the majority of schools.

In a small minority of schools they may be VAT registered in respect of its taxable supplies of goods or services or purchases of goods from other EU Members States. This will arise in the following situations;

    • it makes taxable supplies of goods over €80,000 in a 12-month period; For example, a school tuck shop with a turnover of over €80,000 or
    • it makes taxable supplies of services over €40,000 in a 12-month period.
      Click here to find what constitutes a taxable supply of services for a school.
    • the value of the goods it acquires, or is likely to acquire, from other EU Member States (including Northern Ireland), is more than €41,000 in a 12- month period. For example, if the school purchases laptops from a German supplier for more than €41,000 in a 12-month period.

See link to Financial Guideline – P13 2020/2021

Steps for the Principal and board of management to assess taxable supply of services.

1) Boards of management in schools should regularly monitor their annual rental income from all sources i.e., the total income from sports facilities and car parks.

2) If the annual rental income is less than €40,000 the school will have no VAT obligations and no action will be required.

3) Where the annual rental income exceeds €40,000 the income from sports facilities should be analysed into income from non-profit making organisations and Income from commercial operations.

4) Income from rental of sports facilities to non-profit making organisations can be ignored for VAT purposes.

5) If the Rental income from commercial operations for sports facilities and car parks combined exceeds €40,000 the board will have to apply VAT of 9% to the rental income from the sports facilities and at 23% on the rental from car parks.

6) Click here for a sample VAT invoice for schools to issue to commercial rental customers for sports facilities and for all car park rental customers.

7) The VAT should be included in the bi- monthly Vat return in the T1 box as VAT on Sales.

8) VAT on any relevant expenses should be entered on the VAT return in the T2 box as VAT on Purchases. The school must hold a valid purchase VAT invoice in order to reclaim the VAT charged. Where dual use inputs are used e.g., goods/services used for both a taxable and an exempt activity, a proportion of the VAT may be deducted on the basis of a method of apportionment between taxable and exempt supplies.

How does a school register for VAT?

If you are already registered on ROS for PAYE/PRSI, you can add a new registration using Manage Registration under the Services tab. If not, you can complete the TR1 form which is available to download HERE.

How do I fill out the paper TR1 form? “See instructions listed on the form below.

TR1 Sample Form

Steps for the Principal and board of management to assess taxable supply of services.

1) Boards of management in schools should regularly monitor their annual rental income from all sources i.e., the total income from sports facilities and car parks.

2) If the annual rental income is less than €40,000 the school will have no VAT obligations and no action will be required.

3) Where the annual rental income exceeds €40,000 the income from sports facilities should be analysed into income from non-profit making organisations and Income from commercial operations.

4) Income from rental of sports facilities to non-profit making organisations can be ignored for VAT purposes.

5) If the Rental income from commercial operations for sports facilities and car parks combined exceeds €40,000 the board will have to apply VAT of 9% to the rental income from the sports facilities and at 23% on the rental from car parks.

6) Click here for a sample VAT invoice for schools to issue to commercial rental customers for sports facilities and for all car park rental customers.

7) The VAT should be included in the bi- monthly Vat return in the T1 box as VAT on Sales.

8) VAT on any relevant expenses should be entered on the VAT return in the T2 box as VAT on Purchases. The school must hold a valid purchase VAT invoice in order to reclaim the VAT charged. Where dual use inputs are used e.g., goods/services used for both a taxable and an exempt activity, a proportion of the VAT may be deducted on the basis of a method of apportionment between taxable and exempt supplies.

Invoicing

The subcontractor should invoice to the board of management net of VAT, showing all the information required on a VAT invoice including the VAT number, but excluding the VAT rate and the VAT amount. The invoice should also contain the statement ‘VAT on this supply to be accounted for by the Principal Contractor’. The board should not pay any VAT over to subcontractors. The board should calculate the VAT due on services from the subcontractor and include the VAT in the VAT 3 return as VAT on Sales.

VAT Rate

Current VAT Rate is 13.5%

The following services are liable to VAT at 23% where they are supplied for the purposes of carrying out a relevant operation.

  • Supply and erection of scaffolding
  • Supply of a crane with an operator
  • Supply and erection of temporary fencing
  • Hire of site labour through an agency

Click here to find goods/services exempt from the VAT Reverse Charge

VAT Due

VAT on services received under the reverse charge must be referenced to the earlier of

  • The date the invoice or document is issued
  • The date the payment is made

Or

  • the 15th day of the month following the month in which the person receives the services

Steps for processing a Reverse VAT Invoice

The principal contractor accounts for the VAT on services rendered from a sub-contractor under what is known as the Reverse Charge.

  1. The charge for services by the sub-contractor does not include VAT on the services.
  2. The VAT registered sub-contractor issues an invoice to the principal, which shows all the information as it appears on a VAT invoice except the VAT rate and VAT amount. The invoice should include the VAT registration number of the sub-contractor.
  3. The invoice should also contain the statement ‘VAT ON THIS SUPPLY TO BE ACCOUNTED FOR BY THE PRINCIPAL CONTRACTOR’
  4. The principal contractor pays the sub-contractor for the services. This payment should not include VAT.
  5. If RCT is to be deducted, it should be calculated on the VAT-exclusive amount.
  6. The principal contractor should include the VAT on the services received from the sub-contractor in the VAT return for the period in which the VAT supply in made as VAT on Sales (T1).
  7. In the case of a payment being made in advance of supply , the principal will include the VAT on the payment  in the VAT return for the period in which the payment is made.
  8. Schools would not be entitled to VAT input credit.

When VAT becomes payable

You must file and pay your Value-Added Tax (VAT) by the 19th day of the month following the end of each taxable period.

For ROS filers, the time limit for filing a VAT return is extended to the 23rd day of the month.

You may incur interest and penalties for late, or non-filing and payment, of your VAT.

What are the taxable periods for VAT?

The taxable period is a two-month period (bi-monthly) commencing on the first day of January, March, May, July, September and November. However, the Collector-General may authorise the following taxable periods:

  • annual return, if you are making equal instalments by direct debit
  • four-monthly returns, if your annual VAT liability is between €3,001 and €14,400
  • six-monthly returns, if your annual liability is €3,000 or less.

Completing a VAT Return

When you are ready to complete your VAT return you should log on to ROS. The following should be then be selected:

  • My Services
  • VAT Return
  • VAT 3

Choose the relevant return period e.g. Jan/Feb.

IMPORTANT NOTE: VAT returns are due on the below dates. 

  • 23 March for Jan/Feb
  • 23 May for Mar/April
  • 23 July for May/June
  • 23 September for July/Aug
  • 23 November for Sept/Oct
  • 23 January for Nov/Dec

Remember – A VAT return can only be done through Revenue Online Services (ROS).

The VAT3 return records the Value Added Tax (VAT) payable by you in your taxable period. The return should be completed as follows:

T1 – VAT on sales
Usually ‘0’ except when there is a reverse charge due because of a Relevant Contract.
When RCT is applicable, put the VAT amount in this box ie 13.5% of Relevant Contract.

T2 – VAT on purchases
For Schools always enter ‘0’ in this box

T3 – VAT payable
For schools, this will always be the same as T1

T4 – VAT repayable
This will never be applicable to a school

E1 – Intra-EU supplies of goods
Always enter ‘0’

E2 – Intra-EU acquisitions of goods
Always enter ‘0’

ES1 – Intra-EU supply of service
Always enter ‘0’

ES2 – Intra-EU acquisition of services
Always enter ‘0’

IMPORTANT NOTE: If no VAT is applicable you must still do a ‘nil’ VAT return.

Don’t forget to sign and file, this means entering your password again. The form will not be processed until you complete this step.

What is the Return of Trading Details (RTD)?

  • You must complete a Return of Trading Details (RTD) form annually. The RTD form details the total purchases and sales for the year, broken down by the VAT rate.
  • You must submit your complete RTD form at the end of the year. The form will be displayed in your ROS inbox.

Click here for further guidance on the return of trading details.

Completing the VAT 3 RTD Return of Trader Details

See video below on how to complete a VAT RTD form on ROS

> Watch video

VAT Records to be Kept in Schools

  1. General
    A VAT-registered person must keep full and true records of all business transactions. The records must be kept up to date and must be sufficiently detailed to enable a trader to accurately calculate liability and also to enable Revenue to verify the veracity of the underlying transactions if necessary.
  2. Records of purchases
    The records should show the date of the purchase invoice and a consecutive number (in the order in which the invoices are filed), the name of the supplier, the cost exclusive of VAT and amount of VAT shown or in the case of a contractor the statement “VAT on this supply to be accounted for by the Principal Contractor” must be on the invoice.
  3. Retention of records by accountable persons
    An accountable person must retain all books, records and documents relevant to the business, including invoices, credit and debit notes, receipts, accounts, cash register tally rolls, vouchers, VIES and Intrastat returns, stamped copies of SAD’s and other import documents and bank statements. These business records must be preserved in their original form for six years from the date of the latest transaction to which they refer unless the written permission of the relevant Revenue Office has been obtained for their retention for a shorter period.

Invoices that have been issued in paper form must be retained in paper form. It is now no longer a requirement to retain the paper originals of any third party record where an electronic copy of the original record is generated, recorded and stored in accordance with the information technology and procedural requirements as published. See eBrief Retention of Electronic Records Copies of original invoices produced by microfilming or other copying process are not acceptable.

Records not stored electronically in accordance with SI No. 504 of 2004 and Section 887 of the Taxes Consolidation Act 1997 i.e. paper records, must be stored within the State unless Revenue agrees otherwise, subject to conditions.

  1. Retention of records by taxable persons
    Persons who carry on business, even though they may not be accountable persons, must for VAT purposes keep all invoices issued to them in connection with the business and copies of customs entries in respect of goods imported.
  2. Electronic invoicing and storage
    A person who issues or receives electronic invoices etc. must retain and store them and related electronic records. In addition they must store details such as the form of encryption, electronic signature and details of the format in which they can be accessed.
  3. Inspection of records
    Authorised Revenue officers have extensive powers in regard to the inspection of records and failure by accountable persons or their employees or associates to co-operate with the officers is an offence. These officers will have proof of their identity. They may check the person’s VAT returns against their records and they may cross-check invoices against the suppliers’ and customers’ records. Returns for VAT may also be checked against the trading accounts submitted for other taxes. Failure to produce records on request by an authorised Revenue officer is an offence.

VAT – FAQ’s 

VAT – Reverse Charge FAQ’s – FSSU