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Select Committee on Finance and General Affairs debate -
Friday, 2 Jul 1993

SECTION 10.

Question proposed: "That section 10 stand a part of the Bill."

I understand that under paragraph (b) (a) the power of the Minister to mitigate fines is being reduced. He can now reduce fines by only £50. I have no difficulty with paragraph (b) (b) of this section.

I have had to write to successive Ministers for Finance about a number of Customs and Excise cases, particularly diesel related offences. There are two types of case I came across and one is where the judge says he would have liked to have mitigated the fine but could not. The public representative then writes to the Minister conveying the comments of the judge. Will the Minister, who previously had the power to act in such a case, now have that power removed? The Revenue Commissioners have been seeking for some time to get a compliant Minister to agree to that provision.

It appears to minimise the Minister's democratic input in that area and, ultimately the Minister for Finance, unlike the Revenue Commissioners, is accountable to the people. If the Minister decides to mitigate a fine and I believe that decision is excessively lenient, I can table a Dáil Question on the matter and the Minister is accountable to the House. Decisions by politicians are the most transparent and accountable of all.

The second point is that I invariably come across cases where, say, someone who is a sole trader, did not have limited liability, went out of business, is now on unemployment assistance and being means tested but where there is a clear inability to pay. A common sense provision is required there whereby whatever about the rights and wrongs of it, the person has been convicted and the rigors of the law have been applied. This applies to judgments every day of the week but there is no money to be got from such persons and they are likely not even to own their own house. They may be living in local authority accommodation, so on both of those grounds——

Is this after a judgment?

It would be, yes. In other words, the Minister and his predecessors have had a discretionary power. The Minister is accountable to the public and to the Dáil for his actions, and I am asking what is the need for this? I have no problem in relation to the Bill but I am against the "stroke" appeal commissioner or political fixer business. In relation to lines 7 to 12, in cases of inability to pay, in cases where a judge has said he would like to reduce the amount further, it would be no harm to keep this provision on the Statute Book.

I have no amendments down to this section which relates to section 5 (12) of the Income Tax Act, 1967 and is making a number of amendments to strengthen the provisions. That section says, "the Revenue Commissioners may in their discretion mitigate any fine or penalty, or stay or compound any proceedings for recovery thereof and may also, after judgment, further mitigate or entirely remit the fine or penalty; and may order any person imprisoned for an offence to be discharged before the term of imprisonment has expired. The Minister for Finance may mitigate or remit any such fine or penalty either before or after judgment."

I would be interested to know how much general use is made by the Revenue Commissioners of their power under that section, and how much use has been made by successive Ministers for Finance in respect of mitigating fines or penalties. Can I ask whether the Revenue Commissioners have ever used the power to discharge anyone, before the term of imprisonment has expired, if ever there was such a person who was imprisoned in this State for a tax offence?

They are looking for him now.

I am advised that on the last point the answer is no. What is happening is that the Minister for Finance and the Revenue Commissioners retain the power of mitigation prior to the court judgment. So, on prosecution you still hold the power, but it ceases after the judgment. That is the change. In one case raised by the Deputy, the Minister for Finance would still have the power. It is to stop a situation where the Revenue Commissioners have succeeded in getting a prosecution through and the fine is then halved. With regard to the point raised by Deputy Cox, it is another means of excess whereby somebody can try and get the fine reduced.

What about the excise case?

This applies only to taxes and it would not apply to excise. With regard to the use of powers to discharge, I have never used those powers and I do not believe in using them. The Revenue Commissioners would use the powers commonly based on settlement cases, presumably interest in penalty cases, where there is a settlement to try and conclude and bring a case up to date.

Is that discretion on the part of the Revenue used before or after judgment?

Up to now they were able to use their discretion in both cases but mitigation can only now be applied prior to conviction.

Section 10 agreed to.
SECTION 11.

I move amendment No. 62:

In page 17, line 6, after "section" to insert "if the court is satisfied that the said offence has resulted from a civil fraud, a substantial mis-declaration or significant omissions of material fact, and".

There is a major material difference between section 11 and section 9. Section 9 deals with those people for whom earlier sections were doing a favour. Section 11 deals with everyone, not just for those who want to come clean now but everyone who is in the system carrying the can and paying their way. If there is any false statement in one's tax return or if anyone aids or abets that, we are down to the same question of summary conviction involving a term not exceeding 12 months or on conviction and indictment, a term not exceeding eight years. In other words, this is for everyone, not only those who have been outside the system waiting on amnesties. There has got to be some gradation in this and I have already given the suggestion from the Keith Commission in the UK and from the Commission on Taxation. Whatever about the practice of going to court and prosecuting people, if we legislate without some reference to the degree of seriousness of the misdeclaration, it can be used as a considerable moral suasion on the part of Revenue.

Some cases can be reasonably trivial. I do not think that the law should be entitled to treat in the same way some who had not declared a few hundred pounds interest on money in a bank account and someone who set out through civil fraud to cheat the Revenue up to the eyeballs in respect of due taxes. There have got to be ways of distinguishing between those operating within the law and others.

The Minister said that people have been fined sums of between 5p and £10. This, apparently, is despite the fact that Deputy Dukes had gone to the extent of putting the minimum figure at £1,000 as far back as 1983. There have got to be ways around this. I have used the phrase "that the fines be proportional to the extent of the fraud, the misdeclaration or the omission concerned". I did not define it beyond that because I wanted to put it down as a marker. If however you were to accept that principle you could borrow a phrase from section 10 which states that where mitigation was being considered it could not be greater than 50 per cent of the amount of the fine or penalty. You could put in a minimum amount so that if a judge had the discretion not to go down the imprisonment route in respect of degrees of offence, he could impose a fine of not less than 50 per cent of the tax fiddle it was related to. Revenue is then not going to bring in a 10p tax fiddle for a 5p fine. There could be general proportionality so that if Revenue wanted to follow up the £500 undeclared interest income from a bank account the fine would be a minimum of £250. If it is a case that the fraud was £1 million the minimum fine would be £500,000. I have not put down those amounts because I wanted to establish a discussion on the principle; it is an important principle and it can be provided for. An alternative to putting in the absolute line I suggested, of 50 per cent of the misdeclaration being the minimum fine, is that it might be possible by regulation for the Minister, having consulted the Revenue authorities, to have some scale of value.

We have had a long debate here about civil injury cases and I know that there is always argument if one talks to lawyers. For example if someone was impaired to the point of being blinded in an accident and this was worth £20,000 in a civil injuries case, there is then a row with the lawyer in that if it was the eye of one of the most attractive and well paid models in the world as opposed to that of some old and ugly christian brother who had retired, that the two eyes would not have an equality of value and therefore one cannot put down values. Scales of value can be difficult to determine. In section 11 the Minister is puting down something for every taxpayer in the system and not just for those who are being accommodated by the charter we dealt with earlier. The Minister is saying to all those people, with no de minimus rule, that if they are caught with any false statement, which could be either trivial or major, the only option open to the court is to put them in prison, thereby giving them a criminal record, or to put them into community service with a criminal record. There is no other alternative and that is unreasonable. I do not carry a brief for people who cheat but if some scale of fraudulent intent in the knowing misdeclarations was introduced a set of fines proportional to the offence and a set of offences proportional to the intention could be conceived; both are missing from this legislation.

I would regard it as a very bad piece of legislation if this were to be incorporated in law as the proposition of two wrongs making a right — the bank robber turned vigilante or the poacher turned gamekeeper. We should not balance out all of the offensiveness that one side of this causes to many people by not being reasonable on the other side. I strongly urge the Minister to open up other possibilities. This is not to say to let people off. Get them and hammer them but do so in proportion to the intention of their misrepresentation and in proportion to the effect of the economic worth of the misrepresentation. That is easily drafted. I could draft it before we go to lunch today. I appeal to the Minister to include it.

The Minister talked about the other branch of the administration of justice and the definition of justice. It has its own way and its own modus operandi. It may take the view in many cases that it does not want to leave people with a criminal record which is serious, even for relatively minor offences and even if one did community service. I would not like to think that, because there was no flexibility, future dodgers would get away with things because a court took the view that he or she should not have a criminal record. There must be a way of allowing some discretion to the court, other than imprisonment or a suspended sentence that is proportional to the misdeclaration and where the fine is proportional to the extent of the economic worth of the misdeclaration.

I wish to refer to the concept of jail. I am not opposed in principle to serious tax defaulters going to jail but the purpose of jail is to remove from society people who are a menace, such as people who have a tendency to be violent within the family home or on the streets. I spoke to senior members of the Garda recently and I was horrified to hear statistics that there are approximately 22,000 convictions a year for indictable offences and only approximately 2,000 spaces in prisions. That leads to the revolving door mechanism. The Minister has succeeded in annoying everybody. The PAYE sector is outraged by sections 1 to 8, which deal with the amnesty provisions. Other people, accountants principally, are also annoyed and these new impositions also apply to them. The position is that an accountant can go to jail. The law is quite clear regarding the agent of the person who might argue that he or she was not entirely guilty. A person is guilty of an offence if he or she knowingly makes a false statement or a false representation in any return statement or declaration. This has the potential to put accountants in jail.

What is wrong with that? I would be glad to see people going to jail who knowingly, willingly aid, abet, assist, incite or induce another person to commit crime.

I made the point that there may be cases where the level of tax default goes beyond a fine and should lead to the ultimate sanction of jail. I quote from the Incorporated Law Society in relation to section 11. It states that this section inserts a new section, 516 in the Income Tax Act, 1967, which creates new offences. These offences attract a mandatory prison sentence on summary conviction of 12 months and eight years on indictment. It goes on to state that it also believes that this section is draconian in its terms in that it removes the discretion of the courts.

They are wrong. It is up to 12 months. It is a misreading of the legislation.

It goes on to say, and this disturbs me, that it believes that this section is draconian in its terms in that it removes the discretion of the courts to impose fines where the circumstances disclose minor breaches. Is the society right in that? Fines, in my opinion, would be more suitable in cases of minor breaches.

Cases of minor breaches would not be brought to court.

I wish to make the one final point, that that is right, given the present policy of the Revenue Commissioners and the present chairman and board of the Revenue Commissioners but this law does not presuppose interpretation by administrators. The law is the law as we make it. The fact is that some future chairman and board of the Revenue Commissioners may take a completely different attitude to this. They might consider that they get particular pleasure out of changing that policy, operating the full rigors of the law and throwing the book at the most minor defaulter. The law is there to provide certainty and direct black and white parameters within which the Revenue Commissioners can operate. To state that the present policy is in one direction does not preclude future policy going in a different direction.

The Director of Public Prosecutions will deal with the section. If the Chariman of the Revenue Comissioners or the board do what I would like them to do, which is to track down more of these cases, the Director of Public Prosecutions will not let through spurious cases.

Deputy Yates referred to section 11 (1) (b) and mentioned that accountants could end up behind bars and so on. I am endeavouring to have that covered in one way and still meet the Minister's concern. If an accountant, a solictor or any other professional is knowingly — that is the key phrase — involved in a civil fraud of major and serious proportions, there is no reason they, along with their client, should not face the music. There is another type of music they might face, short of imprisonment, where there is not a gross fraud under the definitions employed by the commission on taxation. I do not have a problem with the principle that those who knowingly give distorted advice or assistance should pay the price. The price is what we are discussing here. Prison may be a price but there could be other penalties.

To be honest, I have no difficulty with the logic of Deputy Cox's argument. However, I must look at the expereince of the past ten years. My experience in this area goes back further but let us take the past ten years.

There are people operating avoidance schemes and involved in evasion, white collar, blue collar, cross-frontier and cross-Border fraud of one kind or another. We are not too sure how they do it all the time, but the Revenue Commissioners are becoming more successful in nailing them down and we learn from that. The legislation of the Statute Book is quite clear. Under section 94 of the 1983 Act, when people involved in fraudulent activities are discovered by the Revenue Commissioners, the inspector puts the case to his superiors, the board makes a decision and a case is prepared. The consent of the Director of Public Prosecutions is obtained and the case goes to court on the basis that these people might be prosecuted successfully. We spent the entire week talking about these non-compliant, heartless criminals of one kind or another who we are now trying to get into the net. What are we going to do? What are we going to leave after this Act? It is not good enough to dodge the point.

The powers are on the Statute Book to put people in prison for up to 12 months, or up to five years for more serious offences, or to be fined £1,000. People have been fined sums as low as 5p. I had to try last year to have a mandatory minimum fine of £200. I am reluctant to put something on the Statute Book that others will read and say that the Houses of the Oireachtas wanted to achieve a more compliant society and under this particular section wanted to put people in jail. I do not want anyone reading the record to be under any illusion. We are trying to put people into jail but if we give a way out, we are back to the stage where, as happened in a recent case, a serious offender prosecuted under section 94 of the 1983 Act which provides for a prison sentence of up to five years was fined 5p. I am open to be persuaded if there is another way, but let me not put something on the Statute Book which only allows people to say that this is even better than the 1983 provision.

No one is asking the Minister to do that.

There was one for £15,500 last week.

Some of these cases involve millions of pounds.

In fairness, no person on this committee has asked the Minister to put in anything that will have someone saying that they know what the Government is at now. It is too much to say that the only penalty is a jail sentence. There is a way to define, in terms of the degree of seiousness of the offence, jail sentences or fines which are proportionate to the scale of the offence. For example, no court would have a discretion in respect of any knowing misdeclaration, whatever its value, to allow a fine which was less than a significant proportion of the direct ecomomic worth of the knowing misdeclaration. It could be 50 per cent of the value of the misdeclaration. In every case, once a person was found guilty they would either be given a prison sentence or have to pay a fine which is proportionate to the direct economic benefit they were getting. The court would have the discretion to take the whole amount but not less than a certain amount. It must be possible to do this. These people will still end up with a record and will be heavily out of pocket but to say that the only way to achieve compliance is to put people in jail is wrong.

People do not have to go to jail.

They could opt for a suspended sentence with community work. The point I am making is that I regard as a silly joke a suspended sentence with community service compared with a hefty fine. What I am suggesting is much more serious than a Mickey Mouse suspended sentence which means no more than sweeping out the local youth club every Saturday.

No one is arguing that tax defaulters should not go to jail in certain circumstances. It would be wrong to try to portray Deputy Cox and myself as being soft on this point.

This is my concern. I sympathise with Deputy Cox but if we do not give a clear signal to the courts and they see a sliding scale, when somebody is in court and caught for £1 million, and the sliding scale for £1 million fraud is £150,000, the courts, in my view, will fine them £150,000. The fact is that a person involved in fraud to the tune of £1 million will be able to pay the £150,000 fine, probably more so than an old lady from Connemara who was charged £1. She will not be in court anyway, but if she were, she would have had more problems getting to court to pay the £1. Therefore, if the man with £39 million — the kind of case we spoke about at length during the week — is caught and has to pay £150,000, he will be delighted to pay it.

I have not asked the Minister to do that.

He will be delighted to pay it. The fact of the matter is that — Deputy Yates asked me this question earlier — in ten years since the Dukes section, if we may so refer to it, one person was imprisoned but the Supreme Court reversed that decision so nobody has been jailed on foot of that section. My concern is that the courts have a job to do, and we have a job to do but I am not against thinking about the section again over the weekend. However, I do not want to give the signal that not only are we soft in this area but we are saying that we prefer fines to imprisonment. I do not want to use the language that has been used during the week about the type of people we are referring to here but those who fail to take up the offer of this amnesty are the ones that I, quite frankly, want to see behind bars. I find it difficult enough to give the others the opportunity to get back into the tax net but I certainly do not want to see the individual who thinks he is smarter than everybody else, and who thinks he is going to get away free, succeed in doing so.

But this law affects everyone. It affects people with no bottom line whatsoever and those who have knowingly made misdeclarations from 2p up to £50 million. That is the point I am making.

If I can find a way to separate one from the other, I will, but has Deputy Cox envisaged that if a person did not pay DIRT of £10 or £100, the Revenue inspector, the Revenue board and their legal people, the DPP and the judge will put them in jail? It is unbelievable that they would——

I envisage a position where the law reflects our intention and if that is not our intention, this law does not reflect that.

The Minister has consistently discredited aspects of the Incorporated Law Society's submission, but I would now like to refer to the Institute of Chartered Accountants.

I only received their letter last night because it was delivered to the Dáil Inquiry Office at 12 o'clock yesterday and my staff only check there twice a day for mail. I only got a chance last night to read the submission briefly.

The Minister has disagreed with most of the points they made anyway, but we will leave that aside. I want to refer to the submission by the Institute of Chartered Accountants in relation to section II. They make a valid point. There is a misunderstanding here because every time we go down this road, the Minister says that this will not happen, that we should simply rely on the law. In their submission, the Institute of Chartered Accountants say:

While we agree fully with the full rigours of the law being applied to tax evaders, we do feel that natural justice could be impaired by not giving the courts the discretion to impose fines or other sanctions besides prison sentences. The legislation, as it now stands, effectively transfers discretion on punishment from the courts to the Revenue and could result in a person being imprisoned for minor offences for matters such as a misinterpretation of what is extremely complex tax——

That is incorrect.

Could you clarify for me where it is incorrect?

Putting this section into the legislation is in no way taking from the powers of the courts. The courts can only base their decisions on what is in legislation and the Revenue Commissioners are not deciding what should be in legislation.

If the Minister looks at line 16, page 17, of the Bill which says that a person guilty of an offence under this section shall be liable to imprisonment, for either 12 months or eight years. I do not see where the judge has discretion. I am not saying that they should not go to jail but it should be left up to the judge to decide, not the Revenue Commissioners.

I said that I will look at this. The letter from the Institute of Chartered Accountants — I will not differ with my esteemed colleagues — states, at the start of the second page that:

The legislation contained in section 94 of the 1983 Finance Act is, we believe, quite adequate to deal with any offence arising under sections 9 and 11 of the Bill

This section has not put anyone in jail for 10 years — it regularly fines people £10 for serious fraud — in a recent case it fined a person 5p. We must try to be at least 5 per cent serious; the section has proved a failure.

I am trying to focus on this because the argument has been slightly misrepresented. The Minister has said that because the Revenue Commissioners have not deliberately pursued, and the DPP and the courts have not processed a whole series of prosecutions, it does not matter what law we make, but that is not my point. My point is that, on principle, there, should be up to eight years imprisonment, but it should be left to the discretion of the judge and not made mandatory because if the Revenue Commissioners changed their policy, then there would be no discretion at all.

I accept that, but can I ask Deputy Yates — he has given a good deal of time to this Bill all week — what signal he wishes to give to the courts? I have been clear in my signals and have been criticised for it and that is why we are receiving these letters. The signal I want to give to the courts is that those who are non-compliant taxpayers, or their advisers who knowingly and wilfully aid, abet, assist, incite or induce another person, should be put in jail. If we give two different signals to the courts, they have already shown us their position. I am not going to criticise them, but the fact is that, under section 19 of the 1983 Act, they have the power to jail people for up to 12 months, or five years in serious cases, and fine them £1,000 but they do not do so. No one has gone to jail for this, apart from one person, who was later released by the Supreme Court. Would the committee be happy that we should tell the courts that those who do not take up this amnesty and so remain non-compliant taxpayers, continue to buck the system, get smart advice and continue to pay nothing to society through taxation, should get a good legal person if they are ever caught to make sure that they will only be fined a small proportion of what they owe? We either tell the courts that this is what we want or else we tell the courts that we wish to see such people locked up.

I want to answer that question because it is a fair one. I would never have considered what the Minister has done in the earlier sections of this Bill because I am satisfied that for the first time, the audit process is working well, it has discovered £200 million in 56,000 cases. The Minister is having to throw the kitchen sink at the latter to give a cloak of political acceptability to the unacceptable earlier provisions in the Bill. It would have been better to change things during the normal course of events through the Finance bill and to look at the penalties. If the Minister feels that the judges are out of line, he should take whatever steps are necessary to bring them into line. He might talk, for instance, with the Master of the High Court. There are often discussions about sentencing policy. There is a number of steps one can take where they should be taken in the normal course of events but this is a kneejerk reaction to the unjustifiable elements in the earlier sections of the Bill, which basically give the message that we will forgive a person, no matter how much of an evader they were. The Minister is going from one extreme to the other. If he had let the audit system run in the normal course of events, it would have dealt with evaders more effectively than will any of these jailing provisions.

When the Minister talks about the signals that should be sent, it is important that they be clear and proportional. In fairness, I acknowledge that the Minister has said he will look at this over the weekend. I hope something comes from it. If one is found guilty, there are only two options that arise out of this; imprisonment or a suspended sentence — one can go to jail or simply sweep the youth club on a Saturday. There must be other intermediate options open to the court. People should not be let off lightly or scot-free. There should be no question of anyone being given the impression that this is only window dressing.

There must be a way of defining monetary fines which are proportional to the scale of the fraud, in terms of its intent, and proportional to the substance and worth of the fraud and the misdeclaration or the misdemeanour in respect of filling out forms in terms of the value to the individual. The section does not give discretion, in that context, to the court to set something to one side, but if jail or a suspended sentence are the only options, my fear is that much of the effect of the Minister's proposal will be suspended sentences. If that turns out to be the case, it is the equivalent, in the Minister's jail philosophy terms, of fines of 5p under the 1983 law. It would be unfortunate if the courts were to consider this to be too heavy a duty or a response, and the judge should decide that he did not wish to put a person in jail and the only penalty could be merely community service. Therefore, there must be an intermediate way of giving substance to the Minister's intention, which includes jail, but which is not, in effect, only community service orders on suspended sentences.

I have noted the points made and will consider them. I will try to find a way to signal to the courts that we are looking for people with substantial resources, to pay a proportion of those fines. The powers contained in section 19 of the 1983 Act brought forward by Deputy Dukes have not been successful in dealing with this matter, in spite of Deputy Dukes's best efforts. If one reads the record of the time, it is clear what he was attempting to do.

Did Fianna Fáil oppose it at the time?

I would have supported it because my speeches at the time——

Would Fianna Fáil have opposed the Government?

(Interruptions.)

I ask my Opposition colleagues to consider the point that if one agrees to a minimum fine as an option, experience shows that one will not secure prison sentences from the courts.

I accept that point and I know the Minister and his advisers are listening carefully. I have not spoken about a minimum fine. I have spoken about fines with a minimum proportionality to the extent of the fraud intended and to the benefit of the individual involved, not a minimum fine of £1,000 or £2,000. If the Minister allowed the courts to impose a minimum fine of 50 per cent of the fraud a person involved in a fraud worth £1 million would lose £.5 million. If the fraud involved £50, he would be fined £25. That is not a minimum fine, it is a minimum proportion of the direct benefit that would have been obtained by cheating.

I am aware of Deputy Cox's views in this regard. However, it must be stated on the record that such difficulties will arise, regardless of this legislation. The temptation for non-compliance exists in society. I appreciate what Deputy Yates said about the work of my colleagues in the Revenue Commissioners. However, there is a large number, whose affairs cannot be analysed and that is why we must use carrots and sticks to clear up these matters.

Amendment, by leave, withdrawn.
Amendments No. 63 to 66, inclusive not moved.
Section 11 agreed to.
SECTION 12.
Question proposed: "That section 12 stand part of the Bill."

This section states that Schedule 15 to the Income Tax Act, 1967, will include various items. What does that mean? What is added to Schedule 15? What might one expect to happen as a result of that?

The failure to make a declaration under the incentive amnesty or the submission of a false declaration under the incentive or general amnesty, in so far as it relates to VAT, will be subject to the penalties provided in sections 500 and 501 of the Income Tax Acts. That is the purpose of this section.

What are those penalties? Are they different from what we have been discussing?

The penalty under section 500 is £750, for failure to make certains returns. Section 501 provides for penalties of £100 plus the amount of tax or in the case of fraud twice the amount of tax evaded where incorrect returns are made.

Are those fines arising from Schedule 15 and sections 500 and 501 of the Income Tax Act, 1967, an alternative or an addition to what we discussed? If this is the alternative, the Minister is enacting a "mickey mouse" alternative after a tough prison sentence. I am not sure if this is what is intended because the way it is written is technical gobbledegook.

They are charges for minor offences.

They are minor penalties for minor offences.

This occurs where the Revenue Commissioners sue for a debt. They are not criminal offences. They are suing for a debt incurred as a result of tax evasion. They are cases where the Revenue Commissioners would not prosecute. They could sue, but usually they do not. It is a debt that is outstanding to them and they would probably make an arrangement with the taxpayer to pay the fine.

I want to be clear about this. Am I correct in saying that this involves, to some degree, fiddling the tax man? This fiddle allows the tax man to reach an agreement which, after discussing prison sentences, could be a three and sixpenny settlement, in respect of what is outstanding. When I read this, it did not mean anything to me. Do such cases go to court?

Usually, such cases do not go to court. They are civil penalties.

Could they go to court? Could the courts use section 12 as a way around section 11? If they can, these are "Mickey Mouse" fines.

They are civil penalties. Where a debt is outstanding agreement could be reached in relation to penalties.

I asked about figures in relation to Appeal Commissioners. Did the Minister get these figures?

We have no details from the Appeal Commissioners. We will try to get them for the Deputy. The Revenue Commissioners do not have the necessary data.

Will the figures be available on Report Stage? Someone should keep a record of this.

I will consider these sections and I may table additional amendments on Report Stage.

Question put and agreed to.
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