With the 15 September deadline now past for declarations of intent to make a qualifying disclosure, media reports have the number of declarations at some 1,600. ICAI understands that the actual figure is higher, and will be closer to 2,000.

But a declaration does not necessarily imply that a disclosure will be made. Over 8,000 declarations were made in the context of the SPIP investigation in 2005, but the number of voluntary disclosures was approximately 4,600 by the disclosure deadline. A further 800 cases rattled out over time subsequently. Because the SPIP and the Deposit Investigation are quire similar in many respects-both concerned investments over a certain threshold which might or might not have been derived from untaxed funds-it is reasonable to expect that the number of qualifying disclosures might be around the 1,000 mark.

Anecdotal evidence from members suggests a relatively high level of concern and uncertainty on the part of individuals with substantial deposits, but matched with a low level of activity in the making of declarations. Further, we gather that some 100 individuals have made disclosures already, with an average yield from these of some €50,000.

The Offshore Assets investigation brought in some €910m, SPIP €450m. Special investigations are bringing in diminishing returns. This could be because tax defaulters are becoming more blasé about Revenue investigation initiatives, but a far more likely explanation is that the concept of tax compliance is becoming more embedded. Compliance rates for the main taxes are well into the 90% range-most Revenue Authorities worldwide would envy the self employed compliance rate of 97%. Yields on published settlements as per the quarterly defaulters lists have dwindled from €31m a year ago, to approximately €20m, and most recently last quarter, €12m.

These trends will have to be taken into account should Revenue consider launching yet another special investigation.