Question
We have a company whose financial year end is 30th April 2019.
The current ARD with the CRO is 31st Jan 2020.
Due to Covid 19 restrictions we are due to complete the B1 filing and upload April 2019 accounts over the next couple of weeks.
Our client wishes to change the accounting period from April to December going forward. So he wishes the next financial year to be 1st May 2019 to 31st December 2019 and then 31st December each year forward.
Can you explain how we can process this with necessary B73 or B83 to effect this change correctly?
I know normally we would only be able to push the ARD using a form B73 forward 6 months which would be 31st July 2020 and a B1 along with a B83 would need to be efiled 28 days later.
However because of the Covid 19 restrictions and the extended deadlines the Jan 2020 B1 needs to be completed still?
As the CRO have extended all deadlines until 31st Oct can you outline how best can we effect this change and filing dates and forms necessary please?
Answer
If you had not filed the B1 online by the 28th February you are facing issues here. The extension period is only valid for annual returns that were due to be filed on or after 18 March 2020. In your case the B1 was due to be filed on the 28 February (28 days after the ARD) so if it has not been filed online, the return is technically late. Therefore the next two years financial statements should be audited and there will be late filing fees – see CRO’s late filing fee calculator online.
In changing the accounting period, you need to be careful that the ARD date is not 9 months after the financial year-end.
If you extending the ARD from 31 January 2020 to 31 July 2020 the 30 April 2019 Financial statements will not be accepted with the B1 as the ARD is nine months after the year-end. Therefore you file upload the 30 April 2019 accounts with the 31 January 2020 ARD.
You must also be careful when preparing the next set of financial statements to 31 December 2019, as your next ARD will then be 31 January 2021. This also nine months after your financial statements. You can however file the annual return on 30 September 2020 (earlier than the ARD) and elect to change the ARD to the return made up to date rather than requesting to retain the existing ARD. This would eliminate the need for a B73. You should however file the B83 under S288(4) which allows companies to change their financial year-end once every 5 years. This would mean you would need to have and upload the 31 December 2019 accounts in October (28 days after the 30 September – the new ARD).
If you had filed the B1 electronically by the 28th February you could go to the CRO and explain how you couldn’t get the signature page in they should be lenient.