New Code of Practice for Revenue Compliance Interventions

The new Code of Practice for Revenue Compliance Interventions has been published by Revenue and sets out a revised framework of compliance interventions. The Code will take effect from 1 May 2022, and will apply to all compliance interventions from that date. Substantial changes have been made to Revenue’s approach to compliance interventions and disclosure opportunities and the issuance of 'aspect queries' will cease from 1 May 2022.

The Institute, under the auspices of CCAB-I, has been engaging with Revenue for several months in relation to the Code and will continue to do so, particularly in relation to the volume and type of interventions that are expected to issue under the new Code. We will update members on the practical aspects of the new framework over the coming weeks.

The new code, which replaces the current Code of Practice for Revenue Audits and other Compliance Interventions 2019, reflects a graduated response to risk and taxpayer behaviour. The graduated interventions are Level 1, 2, and 3.

• Level 1 is considered an intervention to support compliance, i.e., self-reviews, profile interviews, bulk-issue non-filer reminders, etc. The taxpayer retains the right to an unprompted disclosure.
• Level 2 is a risk review audit. This is an intervention to challenge non-compliance and the taxpayer retains the right to a prompted disclosure.
• Level 3 is an investigation and at this point a qualifying disclosure is no longer available to the taxpayer.

The code will cover all taxes and duties with the exception of customs.  

Following ongoing discussions with Revenue, the introduction of the new code has been delayed from an initial date of 1 February 2022 to 1 May 2022 to allow more time for taxpayers and advisors to digest the new code and familiarise themselves with the new processes. Revenue have also committed to training staff in the new code to enable a smooth changeover to the new regime.

Revenue eBrief No 31/22 contains further details. We will cover the updates in more detail in the coming weeks.