Section 54 makes a number of changes to the tax code which will reduce the level of penalty mitigations for tax defaulters with off-shore irregularities giving rise to an Irish tax liability.

The amendments withdraw, from 1 May 2017, the penalty mitigation arrangements, currently available to tax defaulters who make a qualifying disclosure to Revenue, in two situations:

• firstly, where the disclosure relates directly or indirectly to offshore tax defaults, and
• secondly, where the disclosure relates to any other tax default in circumstances where the person has, before the date of the disclosure, certain “offshore matters” that are known or become known to Revenue and which are matters occasioning a liability to tax that gives rise to a penalty.

An “offshore matter” includes any accounts, income, gains or property held outside the State. These amendments take effect from 1 May 2017.