Link Report

(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 (4), a disclosure that the Revenue Commissioners are satisfied is a disclosure of complete information in relation to, and full particulars of, all matters occasioning a liability to tax that gives rise to a penalty referred to in subsection (4), and full particulars of all matters occasioning any liability to tax or duty that gives rise to a penalty referred to in section 116(4) of the Value-Added Tax Consolidation Act 2010, section 134A(2) of the Stamp Duties Consolidation Act 1999 and the application of subsection (4) to the Capital Acquisitions Tax Consolidation Act 2003, and

(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,

(ii) the amount of the difference referred to in subsection (11) or (12), as the case may be, of section 116 of the Value-Added Tax Consolidation Act 2010, or

(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) 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.

a penalty referred to in section 116(4) of the Value-Added Tax Consolidation Act 2010

and sections 115(9) and 116(16) of the Value-Added Tax Consolidation Act 2010

section 116 of the Value-Added Tax Consolidation Act 2010

in subsection (11) or (12), as the case may be, of section 116 of the Value-Added Tax Consolidation Act 2010

section 116(4) of the Value-Added Tax Consolidation Act 2010

(c) The liability imposed on an applicant by this subsection is in addition to the liability imposed by section 116.

(4) Subject to section 116(10), proceedings for the recovery of any penalty under this Act may be commenced at any time within 6 years next after the date on which it was incurred.