Irish Revenue publishes new audit code of conduct

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


Irish Revenue publishes new audit code of conduct

The Revenue Commissioners have published a new code of conduct for audit which outlines the principles and policies of audits and provides practical guidance on how a tax audit will be conducted.

Key changes include improvements to the classification and categories of tax defaults, tax geared penalties and the mitigations that apply.

The improvements were necessary because, in relation to the previous appeal mechanism for penalties, a stronger incentive was needed to make a disclosure to the revenue.

The new code also accommodates the stage payment of arrears and more straightforward settlements, where tax default does not result in a loss of money to the exchequer.

The code clarifies what kind of revenue contact triggers the need to make a disclosure and the consequent penalty mitigation available.

The revenue can also apply to court for a determination of penalties where the taxpayer does not agree, within 30 days, with the revenue's opinion or amended opinion).

"No action is required by a tax compliant business," said Joe Duffy of Matheson Ormsbury Prentice. "Obviously, any tax audits of businesses taking place following 1 October 2010 will be carried out in accordance with the guidelines and provisions in the new Code and businesses will need to acquaint themselves with the new Code where selected for tax audit,"

The code, which took effect from October 1, replaces the existing code reflecting changes to the Finance (No 2) Act 2008.

Advisers are not concerned about the update and say it simply ties the changes to the code, since 2002, and the changes to the Finance Act 2008, together in one document.

"It's a case of old wine in a shiny new bottle," said Feargal O'Rourke of PricewaterhouseCoopers.

"The amendments merely bring the Revenue's policies and procedures in line with the new legislation," said Duffy.

more across site & shared bottom lb ros

More from across our site

Audifina, the sixth-largest firm of its kind in Lithuania, will bring a 90-strong team with offices in Vilnius and Kaunas to RSM’s international platform
As global capability centres use AI to deliver services, MNEs face a fresh wave of PE and TP exposure that their existing playbooks weren't built for
The deal for Comtax hands Ryan immediate scale in Brazil, with a near-70-strong team serving clients from São Paulo
The arrivals of Julio Castro and Adam Blakemore mean the firm has added six tax partners to its global practice since the start of 2025
Tax authorities have gained unprecedented transparency through CbCR, but a new study suggests they may not be looking in the right places
The future chief tax officer will be judged not only on compliance, but on their ability to harness data, technology and AI to support strategic decision-making
More than 200 tier promotions reshaped this year's European rankings as several international firms strengthened their positions in key tax markets
Ryosuke Takemura, OECD policy adviser, countered that the organisation’s role is ‘not to solve these issues one by one’ but to prevent tax disputes in general
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Asia-Pacific Tax Awards
Monica Erasmus-Koen and her Taxtimbre team will be responsible for building the firm’s TP capability in the competitive Netherlands market
Gift this article