Revenue undertakes a range of compliance interventions to check that taxpayers’ tax returns and payments are correct. These interventions include Revenue audits, query letters, interviews with taxpayers and unannounced visits to businesses. In addition, Revenue often conducts compliance projects focused on certain sectors or in relation to specific tax issues.
A new Code of Practice for Revenue Compliance Interventions (“new Code”) will apply to all compliance interventions notified from 1 May 2022. The new Code introduces significant changes to Revenue’s approach to compliance interventions, arising from the introduction of a new three-level system for classifying interventions – the Compliance Intervention Framework. This new Framework has implications for the ways in which taxpayers can address tax defaults identified by Revenue and the penalties that may apply.
Revenue’s approach to compliance interventions that are notified to taxpayers in advance of 1 May 2022 is outlined in the Code of Practice for Revenue Audit and other Compliance Interventions 2019 ("the 2019 Code").
The Institute regularly engages with Revenue on all aspects of the Code and members’ experiences of audits and interventions. You can find out more about the latest developments on the Code and our representations work on this webpage and in our regular updates to Institute members via TaxFax.
The Institute regularly engages with Revenue at the TALC Compliance Interventions Sub-Committee (“TALC Audit”) on all aspects of Revenue’s approach to compliance interventions.
We engaged extensively with Revenue’s Compliance Policy Personnel as Revenue developed its new Code and Compliance Intervention Framework at TALC, in bilateral meetings and through written submissions. During our engagement we raised members’ queries and concerns about the implications of Revenue’s new approach to interventions and the potential risks and costs for taxpayers. We also raised practical issues, such as, the appropriate channel for issuing intervention notifications and communications with Revenue during each stage of the intervention process.
The minutes of the TALC Audit Meetings outline the issues we have discussed with Revenue.
New Code and the Compliance Intervention Framework
February 2018 – Comments on Revenue Manual on Family Employments
December 2014 – Letter to Revenue on reporting of members to professional bodies
Issue 1, Irish Tax Review 2022, (available to members on TaxFind)
Revenue’s new Compliance Intervention Framework
authored by Sarah Waters, Accountant General’s and Strategic Planning Division, Office of the Revenue Commissioners
Finance Act 2021 and the Code of Practice for Revenue Compliance Interventions
authored by Mark Barrett, Ronan Daly Jermyn
The Institute’s Representations on Revenue’s New Compliance Intervention Framework and the New Code
authored by Mary Healy, Tax Policy & Reps Team, Irish Tax Institute
April 2022 – Institute members have complimentary access to the webinar on the new Code and Framework which featured in Stream 3 of the Annual Tax Summit, on 1 April 2022. This webinar includes a presentation by Aidan Lucey, PwC and a Q&A with Sarah Waters from Revenue Accountant General’s and Strategic Planning Division. The recording can be found in the complimentary CPD section on Blackboard Learn.
New Code and Compliance Intervention Framework
Revenue Manuals relating to interventions