I am informed by the Revenue Commissioners that Section 110 companies are assigned to the Financial Services (Banking) District in Revenue's Large Cases Division. As for all taxpayers, Section 110 companies are selected for compliance interventions based on the presence of various risk indicators and interventions are conducted in accordance with the "Code of Practice for Revenue Audit and other Compliance Interventions". The Financial Services (Banking) District has a large number of taxpayers other than Section 110 companies assigned to it.
A number of compliance interventions are currently being undertaken on companies that have advised Revenue that the company is a qualifying company for the purposes of Section 110 Taxes Consolidation Act 1997.
Selection for audit or investigation and any consequent publication will be dependant on the outcome of the ongoing review and will have regard to whether a Qualifying Disclosure was made and accepted in accordance with Section 3 of the Code of Practice.