Discussion on Compliance Issues of Company Account Payments to Individuals
A company planning to register a DAC in Ireland has a platform that allows businesses and individuals to participate in surveys and receive remuneration. Payments from businesses to the company are clear and lawful, but payments to individuals (possibly including minors, elderly Brazilians, etc.) pose challenges due to the lack of contracts and cross-border nature, making lawful payment and bookkeeping difficult. The article analyzes relevant scenarios and seeks professional advice.
We plan to register a company in Ireland (specifically a DAC) and build a website as a system platform. On this platform, various businesses can create surveys about their products, deposit funds into their virtual bank accounts in our system, and then launch survey campaigns. Individual users can also register and have virtual accounts. When an individual completes a survey, their virtual account receives a certain amount of compensation, such as 5 euros. Afterwards, the individual can withdraw the funds to their real bank account.
In this process, we encounter a key issue: when other businesses deposit funds into our account, the business is clear—business-to-business transfers are legal and compliant. But when our company transfers funds to these individual accounts, the situation becomes complex. These individuals have no contractual relationship with us; they may be teenagers aged 15 to 16, or elderly people from Brazil, diverse in geography and demographics. Therefore, we assume that we cannot sign contracts with these people to prove that our payments to them are legal. Websites like freelancer.com and upwork.com also use the same model to pay individuals, but we are unsure how to do it legally.
Specifically, how should we mark these payments in our accounting system? Unfortunately, as a new company, we cannot afford to hire an accountant, so we handle these matters ourselves, but we lack the relevant knowledge and hope someone can help. It should be noted that we are not from Ireland, but from Lithuania.
Thank you for your answer.