I propose to take Questions Nos. 204, 207, 208 and 212 together.
In his Financial Statement to the House on 11 October 2016, Minister Noonan indicated that he would act to restrict the opportunity for tax defaulters with outstanding tax liabilities relating to offshore matters to avail of the voluntary disclosure regime. In line with this undertaking, section 56 of the Finance Act 2016 provided that, as and from 1 May 2017, the making of a qualifying disclosure is no longer permitted where the tax liabilities involved relate to offshore matters.
The period during which a qualifying disclosure could be made to Revenue in relation to offshore matters ended on 4 May 2017. Disclosures received are still being processed and final data will be available shortly. I am advised by Revenue that the number of disclosures exceeds 2,700, with a declared value of more than €79 million. I understand also that the disclosures relate to a range of offshore matters, including foreign sources of employment-related income, foreign pensions, income from overseas property, offshore bank accounts, offshore trusts and offshore funds. A breakdown between tax, interest and penalties of disclosures to date is as follows:
Tax: €48.5 million
Interest: €24.5 million
Penalties: € 6.0 million
The following table provides an analysis of the previously undisclosed income sources and assets that were included in the qualifying disclosures received
Source
|
Percent
|
Pension
|
16%
|
Bank Account
|
17%
|
Shares
|
20%
|
Property
|
29%
|
Offshore Fund
|
4%
|
Trust
|
1%
|
Earned Income
|
3%
|
Inheritance
|
1%
|
Multiple
|
4%
|
Unspecified
|
5%
|
I am advised by Revenue, that a full analysis of disclosures received by county is not currently available, this analysis will be available once all disclosures have been finalised.
For those who have tax liabilities relating to offshore matters and who did not act by the deadline of 4 May 2017 to address them, they now face the prospect of substantially higher penalties, publication in Revenue’s Quarterly List of Tax Defaulters and possible prosecution.
The international environment is changing, with closer cooperation and information-sharing between tax authorities worldwide aimed at identifying those who seek to hide their profits or gains offshore. Revenue is at the forefront of international developments for Automatic Exchange of Information (AEOI), which include the OECD’s Common Reporting Standard (CRS) and the US Foreign Account Tax Compliance Act (FATCA) initiative. Data received under FATCA is currently being examined and it is expected that enquiry letters will be issued later this year to relevant taxpayers, and data under CRS is not expected until 30 September 2017. These initiatives will provide Revenue with considerable amounts of data about offshore accounts, structures and assets, and Revenue has advised me that they are committed to making full and effective use of this information to pursue rigorously anyone who attempts to use such means to evade their tax obligations. It is not possible at this point to estimate the number of prosecutions likely to arise from Revenue’s enquiries relating to data received under AEOI. However, I am advised that cases will be investigated with a view to prosecution where the facts and circumstances warrant such a course of action.
I will continue to fully support Revenue in relation to its pursuit of non-compliant taxpayers and will ensure that they have all the necessary resources required to achieve this objective.