The first phase of the ERR requires any payments made to an employee or Director within the following categories are reported to the Revenue:
1. Remote Working Daily Allowance: Payments up to €3.20 per day to employees working from home to cover additional expenses.
2. Small Benefit Exemption: Non-cash benefits provided to employees, with a combined annual value not exceeding €1,000.
3. Travel and Subsistence Payments: Reimbursements for business-related travel and subsistence expenses, including both vouched and unvouched payments.
Employers are required to submit details of these payments electronically through the Revenue Online Service (ROS). This is the same process in which payroll is reported.
The submission must be made on or before the date of payment to the employee or director
Recognising the administrative adjustments required, Revenue has extended a grace period for compliance. Initially, no penalties or audits were to be imposed before 1 July 2024, which was further extended until 31 December 2024, allowing employers additional time to align their reporting processes with the new requirements. During this period, Revenue will not impose penalties for non-compliance but expects employers to make genuine efforts to meet their reporting obligations.
Employers should review and, if necessary, update their payroll and expense management systems to ensure they can capture and report the required information accurately and in real-time. Engaging with payroll providers or tax advisors may be beneficial to facilitate compliance with ERR.
We see many international employers who will have a fixed expense reimbursement procedure in line with all their international countries, however this makes it difficult to adhere to the new reporting requirements. The simplest approach would be to include expense reimbursements within the payroll process so they can easily be reported on time. Where expense reimbursements are made outside of the payroll process care should be taken to ensure reporting is made in advance of the payment being received.
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