Important Changes in New Code of Practice for Revenue Compliance Interventions

Important Changes in New Code of Practice for Revenue Compliance Interventions

July 11, 2022

Taxpayers Take Note: Important Changes in New Code of Practice for Revenue Compliance Interventions

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.

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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Intervention Level Objective of Level Nature of Interventions within Level Disclosure Availability Expected Outcome
Level 1 Support compliance by reminding taxpayers of their obligations Occurs when Revenue has not already engaged in any detailed examination of taxpayer/issue.

  • Reminder Notification of outstanding tax returns.
  • Request to self-review
  • Profile Interview
  • Interaction under the Co-operative Compliance Framework (CCF)
Unprompted Qualifying Disclosure
  • Tax plus statutory interest
  • Most reduced penalties
  • No publication
  • No Prosecution
Level 2 Confront compliance risks based on the circumstances and behaviour of the taxpayers concerned. Occurs once Revenue has identified a risk/risks in respect of a taxpayer.

  • Audits
  • Risk Review
Prompted Qualifying Disclosure
  • Tax plus statutory interest
  • Reduced penalties
  • No publication
  • No Prosecution
Level 3 Focused on cases displaying risks of suspected fraud and tax evasion
  • Investigations
No Qualifying disclosures
  • Tax plus statutory interest
  • Higher penalties
  • Publication (if threshold conditions met)
  • Prosecution (in certain cases)


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.

Please note: The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation.

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