The second instalment of this investigation trundles on, with somewhere in the order of 80,000 more policies falling into the scope of the examination.

SPIP had previously focused on policies valued at €50,000 or more, and the second phase of the investigation focuses on policies valued between €20,000 and €50,000. We understand from Revenue that High Court orders to secure details of such policies will be sought in respect of 14 life companies before the summer recess. On the pattern of the earlier phase of the investigation, this implies that letters will issue to policy holders in August/September. Per Revenue, assurances of non-prosecution will be available if additional taxes due are paid by 30 November.

A form of declaration to Revenue to be used where no additional liabilities arise will also issue to the policy holders affected. Again, this is similar to the approach taken in the first phase of the investigation.

While we have not had sight of the form of declaration being used this year, the version for the first phase was wide in scope in that it went beyond liabilities arising from the single premium policy at issue. This created difficulties for accountants advising its completion it in good faith and needless correspondence. There is no indication that Revenue thinking has progressed on the matter.