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

Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
Ian Halligan previously led Baker Tilly’s international tax services in the US
Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
The ‘deeply flawed’ report is attempting to derail UN tax convention debates, the Tax Justice Network’s CEO said
Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
The expansion introduces ‘business-level digital capabilities’ for tax professionals, the US tax agency said
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems
Gift this article