Revenue has confirmed that the use of “expression of doubt”, as provided for under section 955(4) TCA 1997, does not extend to situations where a chargeable person, including a company, is unsure as to the correct status of individual(s) engaged by that person. But what are “expressions of doubt” intended to cover, if such an important technical issue where genuine doubt can frequently arise is to be excluded?

eBrief 05/01 also clarifies that in the context of an audit, a decision to open earlier/later years/periods will be taken in accordance the Code of Practice for Revenue Auditors.

eBrief 05/01 is reproduced here.