The Most Dangerous Tax Deadline Misunderstanding

ROS Pay & File Deadline Extended to 18 November 2026

Revenue has confirmed an extended ROS Pay & File deadline to 18 November 2026, but it’s important to understand that this does not apply in every situation.

Every year there’s confusion about whether the filing deadline is 31 October or mid-November and what the deadlines are for  CGT (gains) and CAT (gift/inheritances).

Under tax law, 31 October is still the statutory filing deadline. The November date is an extra concession, but provided certain conditions are met.

Why 31 October still matters

The extension only applies if the conditions are met. Specifically, that you

  • File your return through ROS
  • Pay your balance of tax due through ROS
  • Pay the correct preliminary tax for the current year

If any of these aren’t done, the extension won’t apply.

Income Tax (Form 11)

Normal deadline31 October.
Extended ROS dateYou get until 18 November 2026, but only if you file and pay through ROS and your preliminary tax is not underpaid.
Preliminary taxMust be paid properly or the extension may not apply
Key riskFiling online alone doesn’t mean the extension applies, payment matters too

Capital Acquisitions Tax (CAT) (Gifts & Inheritances)

CAT works differently to Income Tax. The key date is the valuation date, which can be complex, but usually when you become entitled to the benefit (for inheritances this is often (but not always) the Grant of Probate, not when the asset is sold).

CAT filing deadlineCAT returns are generally filed by 31 October based on valuation date
Valuation datesBenefits with valuation dates between 1 January and 31 August are included in the 31 October filing for that year. Benefits between 1 September and 31 December fall into the following year’s 31 October deadline.
ROS extensionA ROS extension concession applies where the CAT return is filed and, again, the tax is paid through ROS.
Property inheritancesRevenue says the extension applies where the return and appropriate payment are made through ROS. A deferral of payment could affect.

Important: Many people assume CAT only becomes payable when an inherited property is sold, and that is not correct. The valuation date can trigger the tax earlier, even if cash hasn’t been received.

If you’re dealing with an inheritance involving property or delayed access to funds, speak to us early so we can plan payment timing or discuss deferral options with Revenue.

You can also have multiple valuation dates, for instance if you receive an advance or part of a bigger inheritance.

Capital Gains Tax (CGT)

CGT is where many taxpayers get caught out because the payment dates and the filing date are completely separate, and the ROS Pay & File extension does not change the statutory CGT position.

CGT payment datesCGT is paid on account in advance of the return. Gains from 1 January to 30 November must be paid by 15 December in that same year. Gains in December must be paid by 31 January of the following year.
Filing deadlineThe gain is then formally returned the following year, usually as part of the Form 11, by 31 October.
ROS extensionRevenue often allows a mid-November ROS extension. This is an administrative concession, but where you meet the Pay & File conditions the Form 11 (including CGT) is generally treated as filed on time. This concession is referenced in  Part 41A-01-03 – Summary of the Pay & File system for direct taxes, as it applies under Full Self Assessment
Preliminary taxThere is no preliminary tax system for CGT. The December and January payments are the statutory payment dates.
Non-Form 11 filersSome taxpayers use Form CG1 and a CGT payment slip instead of a Form 11. The same payment deadlines still apply.

If you’ve sold shares, property (other than your main home), cryptoassets, or business assets during the year, let us know early. CGT deadlines arrive much sooner than most people expect.

Get your accounts done early!

Getting your accounts done early makes everything easier:

  • You’ll know what you owe sooner
  • You avoid last-minute pressure
  • You have time to plan your cash flow

There’s no reason businesses with December year-ends can’t start preparing accounts now. The earlier you start, the fewer surprises you’ll face later in the year.

If you’re unsure how these dates apply to your own situation, or if you’d like to review your position in advance of filing season, feel free to get in touch. Planning ahead is always easier than fixing problems after a deadline has passed.

Lisa

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