Revenue Audits and Compliance Interventions in Ireland: What to Expect

Few letters unsettle a business owner like a notice that Revenue intends to look at the books. Revenue publishes a Code of Practice for Revenue Compliance Interventions that explains the levels of contact, the time you have to respond, how disclosures work and how your cooperation is treated. This guide summarises what the Revenue pages and documents we opened say, in plain language, so that Irish businesses, including those in Dublin, know what to expect. It is general information, not tax advice; for a live intervention, speak to your tax adviser. Questions about what records to hold are covered in our guide to employment record retention periods.

The Code and its dates

Revenue's eBrief No. 031/22, dated 11 February 2022, announced a revised Code of Practice for Revenue Compliance Interventions, to take effect on 1 May 2022. The eBrief describes a "revised framework of compliance interventions" and a range of responses running from opportunities to correct errors voluntarily through to criminal investigation in serious cases of fraud or evasion. The Revenue landing page for the Code states that Revenue, taxpayers and tax practitioners must all follow it, and shows a published date of 15 May 2026 (with the content first published on 2 May 2017). The Code document itself is a long PDF. The copy we were able to read stopped part-way through, so we describe only the parts we could read.

The three levels of intervention

The Code and Revenue's short guide describe three levels. Revenue may start at any level; they are not a fixed sequence. Level 2 and Level 3 notifications state which level applies.

• Level 1, Supporting Compliance. Broad, non-inquiry actions such as reminders for outstanding returns, requests to self-review, profile interviews and engagement under the Co-operative Compliance Framework. Taxpayers can self-correct or make an unprompted qualifying disclosure.
• Level 2, Confronting Non-Compliance. Either a Risk Review (a focused check on one or a few risks) or an Audit (an examination of compliance with tax and duty law, possibly across several taxes and periods). The notification sets out the taxes and periods involved.
• Level 3, Revenue Investigation. Used where serious evasion or a Revenue offence may have occurred. The short guide says there is no opportunity to make a qualifying disclosure at this level.

Notice periods in a Level 2 intervention

According to the short guide and the Code, a Risk Review is deemed to start 28 days after the date of the notification letter, and an Audit starts when Revenue begins examining books and records. A prompted qualifying disclosure can be made within the notice period if you cooperate fully. If you need more time, you can contact Revenue within 21 days of the notice to ask for an additional 60 days to submit a prompted qualifying disclosure, according to the short guide. Because these are time-limited, the first practical step on receipt of a notice is to note the date, the level and the scope, which is also what the short guide suggests.

Self-correction and disclosures

The Code distinguishes several routes, and it matters which one is still open:

• Self-correction without penalty requires written notice to Revenue, a computation and full payment, and a time limit applies. The short guide says that after notification of a Level 2 intervention you can no longer self-correct.
• Unprompted qualifying disclosure is made before a Level 2 or Level 3 notification.
• Prompted qualifying disclosure is made after a Level 2 notification and before the intervention starts.
• A qualifying disclosure must be complete, in writing, include a declaration and include payment of the tax and late-payment interest.

Revenue's landing page describes the benefits of a qualifying disclosure as potentially lowering penalties, keeping your name off the tax defaulters list and preventing prosecution. Disclosures are excluded where an investigation has started or the matter is publicly known, per the Code.

Your obligations and rights

The Code says taxpayers are required by law to cooperate fully, and that partial cooperation does not count as full cooperation. It also says responsibility for correct returns rests solely with the taxpayer, so a tax practitioner cannot take that responsibility from you. Revenue officials must show identification and authorisation, and the Code says they are to act in line with the values of respect, professionalism and integrity. The short guide describes itself as a guide only and refers readers to the Code for rights during an intervention. We could not read the Code's section on review and appeal procedures in the copy we opened, so we do not describe it. The Code text we read also mentions the Tax Appeals Commission only in passing.

Penalties and interest

The Code says statutory interest applies in all cases. It sets penalties by the category of behaviour (for example, careless or deliberate) and by whether you made a disclosure and cooperated fully, and it contains tables of percentages. We have deliberately left those percentages out, because they should be read in the current Code on the day, and because the penalty sections of the copy we opened were incomplete. The Code also covers publication on the list of tax defaulters and prosecution, but we could not read those chapters in detail, so we do not describe them here.

Records: the part you control

The Code notes that proper books and records are a factor in whether a taxpayer took reasonable care. We did not find a current retention period on the pages we opened, so check Revenue's guidance for each tax, and the retention guide linked near the top of this post for the payroll side.

Preparing sensibly: our suggestions

None of the following comes from Revenue; it is our suggestion for organisations that want to be ready:

• Do periodic self-reviews. If you find an error before any notification, the unprompted routes are still open, so a calendar of internal checks can help. Areas such as preliminary tax deadlines and payments and benefit in kind reporting are common housekeeping points for businesses and employers, though Revenue's pages we read do not say which areas it examines most.
• Keep an audit-ready file. Store key returns, workings, contracts and correspondence where finance staff can find them quickly.
• Agree who is the single point of contact. One named person should handle the notice, the diary dates and the communication with your adviser.
• Brief your adviser early. Send them the notice the day you receive it, because the dates above run from the date of the letter.
• Answer fully and consistently. The Code stresses cooperation, so avoid partial or delayed responses.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Does Revenue always start with an audit?

No. The Code says the levels are not a fixed sequence, and Revenue may start at any level. Many Level 1 contacts, such as reminders or requests to self-review, are not audits.

How long do I have after a Level 2 notice?

The short guide says a Risk Review is deemed to start 28 days after the notification letter date, and that you can contact Revenue within 21 days of the notice to ask for an extra 60 days to submit a prompted qualifying disclosure.

Can I still correct an error after I receive a notice?

The short guide says self-correction and unprompted qualifying disclosures are no longer available after notification of a Level 2 intervention, but a prompted qualifying disclosure may be made within the notice period if you cooperate fully.

Does using a tax adviser shift the responsibility?

The Code says responsibility for the correctness of returns rests solely with the taxpayer, even where a practitioner prepared them.

Where can I read the Code?

On revenue.ie, under the Code of Practice and compliance pages, which also link to a short guide. Read the current version on the day.

Revenue's rules change, so use this guide as a starting point and confirm the position on revenue.ie before acting.