Revenue issued a reminder last week outlining the disclosure and settlement opportunity available to businesses to regularise payroll obligations for 2024 and 2025 without the imposition of interest and penalties, following the landmark decision delivered in Supreme Court judgment in The Revenue Commissioners v Karshan (Midlands) Ltd t/a Domino’s Pizzaco. The deadline for making such a disclosure and paying all related taxes is 5pm on Friday 30 January 2026.
The disclosure opportunity gives businesses, that may have misclassified employees as contractors, the mechanism to have the correction treated under the Code of Practice for Revenue Compliance Interventions provided the disclosure is made by the due date and all related liabilities are paid in full via REVPAY or by arranging a Phased Payment Agreement (PPA) when submitting the disclosure.
Full details of the disclosure opportunity are set out in Revenue Guidelines – ‘Settlement arrangement arising from Revenue v Karshan (Midlands) Ltd. trading as Domino’s Pizza’ and are covered in our earlier newsletter item.
In its reminder notice, Revenue clarified that if, after the submission deadline, a business needs to amend details in a disclosure already submitted, such amendments will be accepted in line with the Code of Practice for Revenue Compliance Interventions, provided that:
- the original disclosure was made on a best-efforts basis,
- the amendments do not arise from careless or deliberate behaviour,
- the amendments are not material in nature,
- the declared liability is paid or a PPA is requested, and critically,
- employees who work for the business are properly classified and PAYE/PRSI is being operated through the PAYE system for 2026.
In such cases, Revenue will continue to regard the disclosure as qualifying.
LOADING...