Any outstanding DIRT liabilities in respect of individual account holders are being met by the relevant financial institutions as a result of the look-back audit undertaken by the Revenue Commissioners. In relation to the question of ‘underlying' tax on bogus non-resident accounts, that is, the question of whether the funds in the accounts have been declared for tax purposes by individual depositors, the Revenue Commissioners have advised me that, as they indicated in their 1999 annual report published in July 2000, it is their intention to pursue this issue.
The commissioners have informed me that their present priority is to complete the work arising from the look-back audits of the DIRT liabilities of the financial institutions. The Deputy will be aware that the commissioners are required to report to the Committee of Public Accounts before 1 November 2000 on the results of these audits. I understand that the report is being finalised at present. The issue of "underlying" tax will then be pursued.
It will be for the Revenue Commissioners to decide on the scope of the investigation and the manner in which it is to proceed. At this stage the commissioners have indicated that, given the potential scale of the investigation, they will be considering carefully its implications as regards the use of their resources as well as any legislative aspects that may arise. They have informed me also that, while the circumstances in individual cases would have to be considered, appropriate arrangements for negotiations would be included. I understand that in due course they will also be considering the question of issuing guidelines or a statement of practice to assist tax practitioners in processing cases.
Questions Nos. 24 and 25 taken with Question No. 9.
