Revenue have released a revised Code of Practice for Revenue Compliance Interventions (the “New Code”) which will apply to all interventions notified on or after 1 May 2022.  The Code replaces the current Code of Practice for Revenue Audits and other Compliance Interventions 2019 and applies to all taxes and duties, except for customs duties. The current Code (2019 version) will have continued applicability to any interventions opened before 1 May 2022.

The most fundamental change to the Code relates to Revenue’s revised classification of compliance interventions and taxpayers’ ability to make a qualifying disclosure upon notification of same.

Revenue Compliance Intervention Levels

Under the New Code there will be 3 intervention levels which reflect Revenue’s intention to provide a graduated response to risk and taxpayer behaviour. The New Code makes clear that these levels are not to be considered as a sequence of actions (i.e. Revenue may initiate an intervention at any level without any prior intervention at a lower level, although an intervention at a lower level may lead to a higher level intervention).

All compliance intervention notifications issued from 1 May 2022 will include a reference to their categorisation as Level 1, Level 2 or Level 3 compliance interventions.
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Conclusion

Taxpayers should be assessing areas in their business where a self-review may be needed, thereby allowing for a Level I disclosure opportunity to minimise any potential exposure.