Significant changes to the qualifying disclosure regime will take effect from 1 May 2017 following the amendments introduced in Finance Bill 2016. Taxpayers have until 30th April 2017 to come forward with offshore tax irregularities before the restrictions apply. Revenue recently confirmed to Chartered Accountants Ireland that it will accept calculations based on the roll-up of liabilities to 2006 such that irregularities per-2006 will be taxed at 2006 tax rates and interest will also run from 2006. This approach is reflected in Revenue’s liabilities estimator. Revenue also confirmed that 100% penalties will apply to pre-1991 irregularities but the other benefits of a qualifying disclosure will apply if the disclosure is a full and true disclosure.

Revenue recently published updated guidance on making a disclosure and has produced an explanatory memorandum on the Finance Act 2016 changes as well as FAQs about qualifying disclosures.