Ireland: Ireland’s cooperative compliance framework

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Ireland: Ireland’s cooperative compliance framework

intl-updates-small.jpg
duffy.jpg
stapleton.jpg

Joe Duffy

Kathryn Stapleton

The Irish Revenue Commissioners (Irish Revenue) has relaunched its cooperative compliance framework (CCF) for large cases division (LCD) taxpayers with effect from January 1 2017.

The CCF is designed to promote open communication between Irish Revenue and larger taxpayers, reflecting the mutual interest in being certain about tax liabilities and ensuring there are no surprises in later reviews. It is entirely voluntary.

Ireland originally introduced the CCF in 2005 with a view to managing the tax risks of LCD taxpayers in a more efficient and effective manner. However, following a review of the current operation of the CCF, it was decided to relaunch it. The review included an analysis of feedback received from taxpayers, case managers within Irish Revenue and also the evaluation of best international practice and other frameworks. The results of the review demonstrated that there was a lack of clarity among taxpayers, agents and Irish Revenue case managers regarding the CCF process and what was involved. It was also perceived that there was no clear distinction between taxpayers who opted into the CCF and those who didn't.

The CCF envisages a relationship based on trust and cooperation between Irish Revenue and large businesses where both parties work together to achieve the highest possible level of tax compliance. The main benefits of CCF participation for taxpayers include a dedicated case manager, a reduced level of compliance intervention, an annual face-to-face meeting and an annual risk review plan agreed between the taxpayer and Irish Revenue. On the other hand, taxpayers who do not participate in the CCF will not have a dedicated case manager and instead will be required to route queries or submissions to the Irish Revenue Commissioners through the general LCD customer service team.

The taxpayer has a number of responsibilities under the CCF that include:

  • Compliance with all tax obligations;

  • Performance of self-reviews and to inform Irish Revenue where risks or errors are identified;

  • Consultation with Irish Revenue in advance of undertaking any restructurings, reorganisations or major transactions; and

  • Informing Irish Revenue of economic and sectoral changes/insights.

Irish Revenue has recently undertaken a campaign encouraging eligible taxpayers to sign up to the CCF. Taxpayers wishing to participate in the CCF must make an application to the Irish Revenue LCD division. Acceptance by Irish Revenue of the CCF request is subject to the taxpayer meeting certain compliance criteria and providing certain requested information to the Irish Revenue.

Joe Duffy (joseph.duffy@matheson.com) and Kathryn Stapleton (kathryn.stapleton@matheson.com)

Matheson

Tel: +353 1 232 2000

Website: www.matheson.com

more across site & shared bottom lb ros

More from across our site

As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues
Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour
Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions
The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition
From Instagram content to £100m transactions, the founder of Thomas & Co International discusses building a modern tax and accounting firm for business founders
Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures
Pillar two has been clients’ ‘biggest headache’ but also a driver of growth for MHA, which believes it has the edge over its big four rivals
Public country-by-country reporting is exposing multinational tax data to investors, journalists and competitors, creating fresh risks for businesses
Pillar two compliance is creating unprecedented data demands for multinational tax departments, making closer collaboration with FP&A teams essential for accurate reporting and audit readiness
Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute
Gift this article