Revenue publishes Enhanced Compliance Engagement framework for high wealth individuals

Revenue has published guidance on the new Enhanced Compliance Engagement (ECE) framework within the High Wealth and Financial Services Division (HW&FSD). The guidance provides information on the procedures and operation of the ECE framework. The framework is voluntary and is available to high wealth individual (HWI) taxpayers whose tax affairs are managed within HW&FSD.

The framework is designed to foster a mutually supportive relationship between Revenue and taxpayers by enabling tax computation reviews, encouraging early engagement on significant transactions, and potentially reducing the need for additional enquiries.

The framework consists of two main elements:

• A tax pack compliance review which involves taxpayers submitting the backup tax computations and any supporting documentation to Revenue for review, and
• The option for a HWI taxpayer to seek an opinion/confirmation from Revenue regarding the tax considerations relating to significant transactions.

The benefits to HWI taxpayers include a dedicated case manager, the right of HWI taxpayers to engage with Revenue while still retaining the right to make an unprompted qualifying disclosure, reduced exposure to interest and the opportunity for pre-engagement with Revenue in advance of significant transactions.

The ECE framework allows Revenue to make more efficient use of resources, establish an improved relationship with the HWI taxpayer and providing a better understanding of the HWI taxpayer’s financial and tax profile, thereby minimising the possibility of additional enquiries.

The ECE framework will initially operate on a pilot basis, effective from the second quarter of 2026 and will run until 31 December 2027 at which point it will be reviewed. A HWI taxpayer can choose to engage with the ECE framework at any stage during the pilot and a formal agreement will not be required.