(a) in relation to a penalty referred to in subsection (3), a disclosure that the Commissioners are satisfied is a disclosure of complete information in relation to, and full particulars of, all matters occasioning a liability to duty that gives rise to a penalty referred to in subsection (3), and full particulars of all matters occasioning any liability to tax that gives rise to a penalty referred to in section 1077E(4) of the Taxes Consolidation Act 1997, section 116(4) of the Value-Added Tax Consolidation Act 2010 and the application of section 1077E(4) of the Taxes Consolidation Act 1997 to the Capital Acquisitions Tax Consolidation Act 2003, and

(a) in relation to a penalty referred to in subsection (3), a disclosure that the Commissioners are satisfied is a disclosure of complete information in relation to, and full particulars of, all matters occasioning a liability to duty that gives rise to a penalty referred to in subsection (3), and full particulars of all matters occasioning any liability to tax that gives rise to a penalty referred to in section 1077E(4) of the Taxes Consolidation Act 1997, section 116(4) of the Value-Added Tax Consolidation Act 2010 and the application of section 1077E(4) of the Taxes Consolidation Act 1997 to the Capital Acquisitions Tax Consolidation Act 2003, and

Provisions Referred to in Sections 1052, 1054 and 1077E

(b) Without prejudice to the generality of clause (a), sections 1052, 1053 and 1054 sections 1052, 1054 and 1077E shall apply for the purposes of that clause as if in Schedule 29 there were included in Column 2 a reference to paragraph 14 of the Second Schedule to the Finance Act, 1986.

(4) In proceedings for the recovery of a penalty incurred under this section or under section 1053 under this section, under section 1053 or under section 1077E—

(3) Where the person mentioned in section 1053 or 1077E is a body of persons the secretary shall be liable to a separate penalty of €1,500 or, in the case of deliberate behaviour, €3,000.

(5) Subsection (3) of section 1053 and subsection (9) of section 1077E shall apply for the purposes of this section as it applies for the purposes of section 1053 and of section 1077E.

(5) Subsection (3) of section 1053 and subsection (9) of section 1077E shall apply for the purposes of this section as it applies for the purposes of section 1053 and of section 1077E.

(1) Without prejudice to the generality of section 913(1), Chapter 1 and Chapter 3B of this Part shall, subject to any necessary modifications, apply in relation to capital gains tax, and sections 1052, 1053, 1054 and 1077E, as applied by this section, shall for the purposes of the Capital Gains Tax Acts be construed as if in Schedule 29 there were included—

(9) Sections 987(4) and 1052(4) Sections 530U, 987(4) and 1052(4), subsections (3) and (7) of section 1053, subsections (9) and (17) of section 1077E, and sections 1068 and 1069and sections 26(6) and 27(7) of the Value-Added Tax Act, 1972, , and section 27A(16) of the Value-Added Tax Act 1972 sections 115(9) and 116(16) of the Value-Added Tax Consolidation Act 2010, shall, with any necessary modifications, apply for the purposes of this section as they apply for the purposes of those sections, including, in the case of such of those sections as are applied by the Capital Gains Tax Acts, the Corporation Tax Acts, or Part VI of the Finance Act, 1983, the purposes of those sections as so applied.

(a) the Revenue Commissioners are satisfied that, before any investigation or inquiry had been started by them or by any of their officers into any matter occasioning a liability referred to in those paragraphs, the person had voluntarily furnished to them a qualifying disclosure (within the meaning of section 1077E, section 116 of the Value-Added Tax Consolidation Act 2010 or section 134A of the Stamp Duties Consolidation Act 1999, as the case may be) in relation to and full particulars of that matter,

(i) the amount of the difference referred to in subsection (11) or (12), as the case may be, of section 1077E,

(b) Any claim in respect of a specified amount shall be deemed for the purposes of section 1077E to be a claim in connection with a credit and, for the purposes of determining an amount in accordance with section 1077E(11) or 1077E(12), a reference to an amount of tax that would have been payable for the relevant periods by the person concerned shall be read as if it were a reference to a specified amount.

(b) Any claim in respect of a specified amount shall be deemed for the purposes of section 1077E to be a claim in connection with a credit and, for the purposes of determining an amount in accordance with section 1077E(11) or 1077E(12), a reference to an amount of tax that would have been payable for the relevant periods by the person concerned shall be read as if it were a reference to a specified amount.

(b) Any claim in respect of a specified amount shall be deemed for the purposes of section 1077E to be a claim in connection with a credit and, for the purposes of determining an amount in accordance with section 1077E(11) or 1077E(12), a reference to an amount of tax that would have been payable for the relevant periods by the person concerned shall be read as if it were a reference to a specified amount.

(1)Section 1077E shall apply to statements made under Chapter 6, and the following provisions shall apply:

(a) in subsections (2) and (5) of section 1077E, the provision to an investor of—

(b) for the purposes of subsections (4) and (7) of section 1077E—

(i) 25 per cent of the amount referred to in subsections (1) and (3) of section 508U shall be treated as an amount calculated under section 1077E(11);

(ii) where an assessment is made pursuant to section 508W(1)(a)(i), the amount calculated in accordance with section 1077E(11) shall be treated as a tax liability of the company which provided the statement to the specified individual;

(c) subsection (11) of section 1077E shall have effect as if—

(1) In proceedings for the recovery of a penalty under section 530F or the recovery of a penalty under section 1052, 1054 or 1077E in relation to matters arising under this Chapter—

(16) Section 987(4), subsection (4) of section 1052 (other than as that subsection applies in relation to proceedings for the recovery of a penalty in relation to a return referred to in sections 879 and 880), subsections (3) and (7) of section 1053 subsections (9) and (17) of section 1077E and sections 1068 and 1069 shall, with any necessary modifications, apply for the purposes of this section and any regulations made under this section as they apply for the purposes of those provisions.

(b) Paragraph (a) shall not apply in relation to a transaction where a person has, in submitting any return, declaration, statement or account or making any claim which purports to obtain the benefit of that tax advantage, incurred a penalty under section 1077E(2) or 1077E(5), section 116(2) or 116(5) of the Value-Added Tax Consolidation Act 2010, section 134A of the Stamp Duties Consolidation Act 1999 or section 58 of the Capital Acquisitions Tax Consolidation Act 2003.

(b) Where the conditions set out in paragraph (c) are met, a transfer pricing adjustment shall not be taken into account in determining whether a penalty referred to in section 1077E(5) applies to the relevant person for a chargeable period or in computing the amount of any such penalty.