I am advised by Revenue that its clear preference is to always engage directly with taxpayers and businesses that are experiencing temporary cash-flow difficulties rather than deploying debt collection/enforcement sanctions.
However, any such engagement is predicated on open and honest discussion by the taxpayer/business, including a willingness to identify and agree a mutually satisfactory payment arrangement. The arrangement will always include an interest element, which is a statutory charge that Revenue has no discretion on, and will require a clear commitment from the taxpayer/business to pay future taxes as they fall due.
Revenue has also assured me that cases are only referred to the Sheriff or to an external solicitor as a last alternative where discussions with the taxpayer/business have failed to resolve the issue. Once a tax debt is referred to the Sheriff or external solicitor, Revenue generally ceases to negotiate directly with the taxpayer/business.
Revenue does of course continue to negotiate directly with the taxpayer/business on all issues other than the specific debt that was referred to the Sheriff or external solicitor. Revenue may also, in exceptional circumstances, agree to re-engage with the taxpayer/business in relation to the referred debt where relevant and previously unknown issues subsequently arise. However any such re-engagement will require the taxpayer/business to firstly pay any fees or expenses already incurred by the enforcement agent.
If there are particular issues that have arisen in a case since it was referred for debt collection/enforcement, then the Deputy should advise the taxpayer/business to make immediate contact with Revenue. If there are no emerging issues, the Deputy should advise the taxpayer/business to engage with the Sheriff or external solicitor who have discretion to agree a mutually suitable payment arrangement.
Revenue has taken a very proactive approach to taxpayers/businesses experiencing difficulty in paying their taxes. I strongly advise any taxpayers/ businesses in difficulty to engage early with Revenue and not to ignore demands for payment. Enforcement is a last resort and the system would cease to work effectively if following referral the taxpayer/business could re-open negotiations directly with Revenue.