Revenue have provided ICAI with further details of the latest phase of the SPIP investigation through TALC.

5,000 enquiry letters issued on 30 March, to which Revenue have received 1,800 responses of one form or another to date. Cases have been selected, in part at least, based on what Revenue would regard as unsatisfactory declarations following the notices issued by the various insurance companies. It seems that these can include cases where a settlement has already been made, or where not all individual policies were covered by a specific declaration, or where Revenue have chosen to disregard correspondence because it didn't fit in with their pro-forma declarations.

In very many instances therefore, there will be no issues-the letters are being sent because boxes within Revenue were not ticked.

While it is evident from the figures already published that there were significant tax irregularities associated with SPIPs, and that Revenue have a large number of cases to deal with, many accountants and taxpayers are now having to deal with unnecessary further correspondence on issues already dealt with.

ICAI have also clarified that, even at this stage of the investigation, Revenue are indifferent to whether or not it is the company or the individual who pays the tax settlement. We clarified that this approach applies notwithstanding the penalty mitigation position which might be available-there are situations where the penalty mitigation could be higher for the individual or the company depending on past Revenue audit track record. Also, where the company makes a tax settlement on behalf of an individual, any notional benefit attributable to the individual will be disregarded for tax purposes.