Friday, 6 September 2019

Questions (60)

Michael McGrath


60. Deputy Michael McGrath asked the Minister for Finance the number of instances and the value of tax involved in recent years in which the large cases division of the Revenue Commissioners issued reassessments of the amount of tax due; the circumstances in which such reassessments may arise; if this only arises in cases in which new information comes to light; and if he will make a statement on the matter. [34814/19]

View answer

Written answers (Question to Finance)

I am advised by Revenue that Large Cases Division was split into two Divisions in May 2018. The new Divisions are: Large Corporates Division (LCD) and Large Cases-High Wealth Individuals Division (LC- HWI). 

The following table below, which reflects the combined LCD and LCD-HWI, sets out the number of instances where an original assessment was amended for the 4 years 2015 to 2018. The Table also sets out the increase in tax liability arising from the amended assessments.


Number of amended assessments

Amount of original assessments

(€ billion)

Increase in liability from amending the assessments

(€ billion)


(€ billion)


























Revenue has confirmed that a significant portion of the increased liabilities arising from the amended assessments set out in the table are currently under appeal to the independent Tax Appeals Commission. Revenue has also confirmed that there is no relationship between the year in which the assessment is amended and the tax year or accounting period to which the liability relates.

The circumstances where assessments may be amended include:

- The outcome of a Revenue audit or other compliance intervention.

- A disclosure by the taxpayer that the original assessment was incorrect (a disclosure may be entirely unprompted or may be prompted following the receipt of a letter from Revenue indicating that it is going to start an audit or other compliance intervention).

- Where a tax return contains an ‘expression of doubt’ on a tax issue and Revenue subsequently disagrees with the position taken.

- Where an additional tax liability is identified following discussions between a taxpayer and Revenue on a technical interpretation.