I refer the Deputy to my answer to parliamentary Question No. 2 of 17 May 2001 in reply to a question about persons complying with the terms of the Revenue statement of practice.
I understand from the Revenue Commissioners that the clear indications are that most of the bogus non-resident accounts identified during the DIRT look-back exercise were in existence before 1991. There was, therefore, an obligation on the account holders concerned to comply with the terms of the 1993 amnesty but it is not known how many of them did not participate at all in the amnesty or how many participated but did not make a full disclosure. A person who complied with the terms of the 1993 legislation would have been able to satisfy all liabilities, including tax, interest and penalties, with a payment of 15% of the amounts of income undeclared.
I am advised by the Revenue Commissioners that both categories of bogus account holders come within the scope of the statement of practice and will now be subject to a significantly more severe regime provided for in the statement. A person who did not comply at all with the amnesty will now have to pay all of the tax liability and, in addition, an amount in respect of interest and penalties. Under the statement of practice that additional amount is capped at 100% of the tax.