I am advised by the Revenue Commissioners that, as a matter of routine, all new OMSP declarations and-or amendments to existing declarations are the subject of review. The nature of the records maintained by the Revenue Commissioners is such that the considerable volume of data requested by the Deputy could not be supplied without an extensive physical examination of more than 30,000 files.
Nevertheless, I am advised that in many instances the review process has resulted in an amendment to the original OMSP. The number of cases that have progressed beyond this point and developed into more formal disputes is small. It is estimated to be less than 100 over the lifetime of the tax. So far only one case has been heard by the courts. It is not possible to go into detail about the case for reasons of confidentiality.