A TAIN gives taxpayer representatives such as tax agents, solicitors, payroll agents, customs agents and other advisers access to functionality in the online Revenue system (ROS), including enabling representatives to file returns, make payments, request clearance, submit notifications or applications and submit enquiries on behalf of clients.

Having and using a TAIN

For the last few years, particularly as online developments for Capital Taxes were being rolled out, Revenue took more proactive steps to provide assurance to solicitors about having and using a TAIN. When the Law Society and solicitors objected to being considered ‘agents’, Revenue changed the ‘language’ around TAIN to clearly show that it understood that solicitors are more likely to have ‘transactional’ relationships with clients as opposed to ongoing ‘tax agent’ links. The TAIN functionality is applicable to all representative relationships, and the updating of the language around TAIN to cover both ‘Tax agent’ and ‘Transaction advisory’ was to provide that level of assurance to solicitors.

With the importance of data security and data confidentiality under the General Data Protection Regulations (GDPR), the functionality that the use of a TAIN provides is crucial to the adherence of representatives to these regulations. The TAIN allows a representative to 

• separate their own personal/business tax affairs on ROS from those of their clients and

• submit queries, file returns and make payments to Revenue under the PPSN of their client and not their own tax registration number. 

This functionality is key to a representative in their administration of both their own and their client’s tax affairs.

Applying for a TAIN 

Before you can be identified as a representative or advisor for a client, you will need to apply to Revenue to get a TAIN number for your firm:

1. Complete the 'Application for a TAIN' form. 
2. Send the completed form to Revenue, along with a 'Transaction Advisory Link Notification' form with details of your first client that you wish to link to as an advisor. This once off step is required so that your TAIN can be set up on Revenue’s systems. 
3. The completed forms can be submitted through ROS or by post to the following address: National TAIN Register, Office of the Revenue Commissioners, P.O. Box 1, Wexford. 
4. For more information, see revenue guidelines on the use of a TAIN

Getting a ROS digital certificate

Once you have been advised that you have a TAIN, you can apply for a ROS certificate for that TAIN. The process is the same as applying for any ROS certificate. If you are unsure about the steps in getting a ROS certificate, view this useful short video: 'How to register for Revenue Online Service'.

Having a ROS certificate for your TAIN means that you have access to the ‘advisor’ functionality in ROS including the ‘TAIN Services’ tab. Accessing MyEnquiries in ROS gives you the ability to submit enquiries on your clients’ behalf, using their Taxpayer Reference Numbers rather than your own PPSN or taxpayer reference number. Such enquiries are linked both to your clients’ tax record and to you as an advisor/representative, but not to your own personal tax record.

Clearance

There is a ‘deemed clearance’ process for clearance in deceased cases that was agreed with the Law Society and the other practitioner bodies through TALC.  The ‘deemed clearance’ process is administrative in nature and is underpinned by a Tax and Duty Manual (TDM).  That TDM sets out the necessary steps that both parties undertake to follow to make the streamlined and speedier process work efficiently. The latest details of updates to the TDM are set out paragraph by paragraph in eBrief 146/24. It is important that any solicitors administering an estate read through the full TDM to ensure that they are fully aware of the requirements to be met to receive clearance for an estate. Any failure to adhere to these requirements will only lead to additional delays for yourself and other solicitors trying to get clearance through this process. Some key points to note in the updated TDM are as follows:

• Appendix 1 sets out the due diligence required to be undertaken by the personal representative in the form of a questionnaire.
  • Download A Tax Clearance Due Dilligence Questionnaire in Administration of Estates

• Appendix 7 'Using a TAIN when submitting a clearance request' gives guidance on submitting a clearance request using your TAIN and not your own PPSN or tax registration number. 

• Appendix 8 'Registering an Estate using eRegistration' gives guidance on how to register an estate online. In a case where it is necessary to register an estate you:

1. Select 'Register a Trust' 
2. Under the 'Trust Type' select 'Estate'. 
3. Then select the 'Appointee Type' which will be either the Executor, Administrator or Personal Representative. We would recommend using 'Executor' or 'Administrator' if completing this before a grant has issued and with 'Personal Representative' if the grant has already issued. 
4. Doing this successfully will generate a 'client consent letter' which your client signs. 
5. Once this is uploaded to Revenue, they will generate a tax registration number for the estate.

One crucial and important change for solicitors is that the 35-working day clearance regime will not take effect if you apply using your own PPSN/tax registration number and not your TAIN number. The ‘clock’ for the 35-day clearance will only begin if you apply using your TAIN number.

When you are opening a new administration file, meeting with your client to do Know Your Client (KYC) / Anti-Money Laundering (AML) and giving them your section 150 notice/retainer to read, sign and return, you could also give them a Transaction Advisory Link Notation to read, sign and return. In addition, if a beneficiary asks you to complete an online IT 38 return on their behalf, you will need to do the same thing.