Revenue Investigation & Qualifying Disclosure FAQs
- General Information
- Benefits of Qualifying Disclosure
- Eligibility Issues
- Types of Trusts & Structures
- Calculation Issues
General Information
The investigations carried out by Revenue into the transmissions of assets and monies to and from offshore sources revealed the use of trusts and offshore structures by Irish residents. The probing of the financial transactions and information further revealed that the transfers and settlements of assets and monies on the structures represented a tax risk. Legislation introduced in the Finance (No 2) Act 2008 requires Third Parties, such as, accountants, tax practitioners, solicitors and financial institutions to deliver certain information on settlements made by Irish resident and ordinarily resident persons involving non-resident trustees.
What does the term "trusts and offshore structures" include?
The term "trusts and offshore structures" covers all categories of trusts (whether Irish or foreign) and offshore special purpose vehicles, entities, arrangements, agreements or rights - including, but not limited to, trusts, trust enterprises, foundations [stiftung], establishments [anstalt], offshore companies, nominee entities, employee / director benefit trusts and incentive plans, investment schemes / funds and investment partnerships.
What is the scope of the Revenue investigation and what tax years will be covered?
The investigation, which starts on 1 September 2009, will examine the use of trusts [whether Irish or foreign] and offshore structures, such as, special purpose vehicles, offshore companies, foundations, establishments and investment funds, by persons [including companies]. This investigation is targeting those persons who have not disclosed the existence of their trusts and offshore structures to Revenue and who have undeclared tax liabilities on the underlying funds, the income and gains arising within the trusts / structures, and disbursements made out of the trusts / structures. The enquiries will cover all historic years for which there are tax issues. The experience from Revenue's earlier investigations is that the use of trusts and offshore structures by persons over the years represents a tax risk and hence the focus will be on all years for which there are undeclared tax liabilities.
What is the focus of the Revenue investigation?
The Revenue investigation will focus on identifying undeclared tax liabilities by persons who have transferred or settled property, assets or funds to / on trusts [whether foreign or Irish] or offshore structures. The investigation will include an examination of the tax returns and the reporting compliance requirements of the individual transferors and settlors. The enquiries will examine the nature and quality of the trusts and offshore structures, the tax treatment of the underlying funds transferred to or settled on the structures, and the income and gains arsing under the structures as well as any disbursements made out of the structures.
Will the Revenue investigation be examining tax years prior to the period covered by Third Party reporting [section 896A Taxes Consolidation Act 1997]?
The investigation itself will cover all back years for which there are undeclared tax liabilities - it is not confined to the years for which Third Party returns will be made to Revenue.
Will the Revenue investigation be confined to certain offshore locations or structures?
The Revenue investigation is not confined to particular offshore locations or structures - the experience from earlier Revenue investigations is that the patterns and methodologies used in the transmission offshore and repatriation of assets and funds, and the use of structures, are varied and hence the investigation will not be limited by reference to the location or the nature of the structures.
Is the Revenue investigation likely to involve "follow-up" enquiries with financial institutions and other Third Parties in relation to returns made in respect of the years from 24 December 2003 and will enquiries be made in relation to settlements on trusts in any earlier years?
The information received on the section 896A returns from the financial institutions and other Third Parties will be examined and evaluated as part of Revenue’s investigation into trusts and offshore structures. The investigation will involve “follow-up” enquiries where this is considered necessary as part of the investigation and examination process. The Finance (No 2) Act 2008 allows for the issue of a notice by a Revenue Authorised Officer to any person [such as, financial institution, company and trustee] where there is reason to believe that the person has information relating to a settlement, requiring the delivery of such information. The issue of such a notice can apply to settlements made pre or post 24 December 2003.
Could the investigation work involve the use of other legislative powers contained in the Taxes Acts?
The legislative powers which are contained in the Taxes Acts may be used in assisting with the investigation generally and the examination of the tax position of cases under enquiry. Such legislative powers may be used, for example, in seeking - from taxpayers, financial institutions and other Third Parties - the production of documentation, information and particulars that are relevant to the tax liabilities of persons who have settled or transferred assets and / or funds on / to trusts and offshore structures.
Will the investigation examine undeclared liabilities of persons [whether individuals, companies or trustees] in relation to funds transferred to an offshore trust structure in, say, the 1980's?
Yes. The investigation will involve an examination of cases with undeclared tax liabilities for all years.
Are both Irish and foreign trust structures within the scope of the investigation?
Yes. The investigation is focused on both Irish and foreign trusts and other offshore structures. Persons with undeclared tax liabilities in respect of such trusts or structures may avail of a qualifying disclosure by delivering a Notice of Intention by 1 September 2009 and making a Disclosure and Payment by 31 October 2009.
What period does the Third Party reporting cover and when will the returns be delivered to Revenue?
The Third Party reporting refers to settlements made on or after 24 December 2003 and the returns will be delivered to Revenue from mid 2009. The legislation also allows a Revenue Authorised Officer to issue a notice in writing to any person, where there is reason to believe that the person has information relating to a settlement, requiring the furnishing of such information. The notice can apply to settlements made pre or post 24 December 2003 and applies to settlements of assets or monies involving either Irish or non-resident trustees.
What information will be reported by Third Parties?
The returns will give the names and addresses of the Irish resident / ordinarily resident settlors and the non-resident trustees as well as the dates of the settlements.
What is meant by the term "settlement"?
The term "settlement" includes any disposition, trust, covenant, agreement or arrangement, and any transfer of money or other property or of any right to money or other property.
Benefits of Qualifying Disclosure
On 1 September 2009 the Revenue Commissioners will commence their investigation of the tax treatment of property, assets and funds transferred to or settled on trusts and offshore structures. In advance of this Revenue are encouraging taxpayers who have tax issues relating to such transfers or settlements on trusts or other structures to come forward prior to 1 September 2009.
Taxpayers who deliver a Notice of Intention before that date will pay a reduced penalty and the details of the settlement will not be published in Iris Oifiguil. Additionally, Revenue will not consider initiating a prosecution. The payment, declaration and computation must be made on or before 31 October 2009.
What are the requirements for availing of a Qualifying Disclosure?
The Revenue investigation will commence on 1 September 2009 and this is the deadline for delivery of the Notice of Intention. The deadline for delivery of the Disclosure and Payment of liabilities is 31 October 2009. Persons who have tax issues arising from assets or monies settled on trusts or offshore structures should avail of the earliest opportunity to resolve those issues with the Revenue Commissioners.
What advantage is there for me to disclose now?
You will receive the benefits of making a qualifying disclosure which are:
- the penalty for underpaid tax will be substantially mitigated;
- your name and payment amount will not be published by Revenue in the quarterly list of tax defaulters in Iris Oifiguil;
- Revenue will not seek to initiate an investigation with a view to prosecution.
What if I don't come forward to disclose my undeclared income or gains held in my trust or offshore structure?
When Revenue discovers that a person has failed to make a qualifying disclosure, that person will be vigorously pursued for unpaid liabilities. The monetary penalty will not be mitigated. The individual's or company's name will be published in the list of tax defaulters in Iris Oifiguil in accordance with section 1086 of the Taxes Consolidation Act 1997 and the individual or company may also be investigated with a view to criminal prosecution for tax evasion.
Eligibility Issues
The benefits of an unprompted qualifying disclosure will apply to persons [subject to certain excluded categories] where a Notice of Intention is delivered by 1 September 2009 and Disclosure and Payment of the undeclared liabilities is made by 31 October 2009. The Revenue Explanatory Note of March 2009 outlines the conditions to be met in regard to the preparation of computations of liability and the making of a disclosure.
The following questions and answers address a number of queries that have been raised on the matter of eligibility to avail of the benefits of the Qualifying Disclosure Initiative.
A taxpayer settled funds on an offshore trust structure 15 years ago. The settled funds consisted of proceeds from the sale of property on which capital gains tax was paid. The individual also had offshore bank deposit accounts for a number of years in his own right [i.e. separate and distinct from the trust]. A disclosure was made of the undeclared income in respect of the offshore bank accounts under the earlier Revenue offshore scheme but the trust source was not disclosed. The individual was of the view that there were no tax issues in regard to the trust structure. A close review of the trust structure and the financial records and accounts for the intervening years indicates now that there was tax exposure. Is the individual eligible to avail of the benefits of the qualifying disclosure initiative?
Where the failure to disclose the offshore trust source under an earlier Revenue disclosure initiative was caused by a misunderstanding or incorrect view of the relevant tax treatment applying to settled assets or funds, and the underlying settled funds consisted of taxed income or gains or were exempt from taxation or had no taxation liabilities, the benefits of the current qualifying disclosure initiative will be regarded as continuing to apply provided a full disclosure of the undeclared liabilities is now made and the Notice of Intention is delivered by 1 September 2009 and the Declaration and Payment is made by 31 October 2009.
A taxpayer held foreign bank deposit accounts over the years and also transferred monies to a foreign trust structure. The individual did not disclose the offshore bank accounts or the funds held in the trust structure under the earlier Revenue offshore scheme. The individual wishes to deliver a Notice of Intention to Disclose ahead of the commencement date [1 September 2009] for the Revenue investigation into Trusts & Offshore Structures. What approach will be taken by Revenue in relation to the disclosure?
Where a taxpayer makes a full disclosure and payment by 31 October 2009 of all undeclared liabilities [as well as delivery by 1 September 2009 of a Notice outlining the Intention to Disclose] the payment of the tax, interest and penalties associated with the undeclared liabilities will be accepted in lieu of initiating any criminal investigation. The approach outlined in the Explanatory Note of March 2009 in regard to the calculation of tax and interest for years prior to 1997/98 may be followed. The individual will not be entitled to an unprompted qualifying disclosure and the penalties should be calculated in accordance with the Code of Practice for Revenue Auditors. The provisions of section 1086 of the Taxes Consolidation Act 1997 in relation to publication of details of the tax settlement will also apply. In the event that a taxpayer has taxation liabilities and fails to deliver a Notice of Intention by 1 September 2009 and make a Disclosure and Payment by 31 October 2009 the Revenue Commissioners reserve the right to consider initiating a criminal prosecution.
A taxpayer transferred funds to a non-resident trustee some 10 years ago and the funds were invested in an offshore trust structure. Neither the underlying settled funds nor the profits and gains arising from the trust structure over the years were declared for tax purposes. Where the individual is not within any of the categories that were required to make a disclosure under an earlier Revenue disclosure scheme may s/he avail of the qualifying disclosure initiative?
Yes. The individual may avail of the benefits of an unprompted qualifying disclosure - again, the Notice of Intention should be delivered by 1 September 2009 and the Disclosure and Payment should be made by 31 October 2009.
An individual was non-resident for tax purposes in the 1990's and while working abroad she opened a foreign bank account and before returning to the State she closed the account and transferred the balance on the account to a foreign trust enterprise. The individual is not within any of the categories that were required to make a disclosure under an earlier Revenue disclosure scheme. What is the position as regards entitlement under the Initiative?
The benefits of an unprompted qualifying disclosure will apply to any undeclared liabilities relating to the trust enterprise – the rules as set out in the Explanatory Leaflet as regards delivery of a Notice of Intention and Disclosure & Payment should be followed.
An individual settled assets and funds on an offshore trust some 20 years ago. Although the trust structure, as such, was in place the individual [settlor] retained effective control and influence over the trustees after the assets and funds had been placed in trust – the trustees had only nominal control of the assets and funds. Does the qualifying disclosure initiative apply to the individual in relation to undeclared liabilities? Would a "look through" basis apply in relation to computing the income and gains concerned?
The Revenue investigation will be concerned with examining the nature and quality of the trusts and other offshore structures. The enquiries will focus on the tax treatment of the underlying assets and funds, the income and gains arising under the structures, and any disbursements made out of the structures. The computations of the income and gains should be made on a "look through" basis in the circumstances outlined and the benefits of the initiative may be availed of by the individual.
Undeclared capital acquisitions tax liabilities arose due to the use of Perpetual or Dynasty type non-resident trusts – does the initiative apply to the undeclared CAT liabilities?
The benefits of the initiative may be availed of in relation to the undeclared CAT liabilities.
Discretionary Trust Tax is owing for a number of years in the case of a foreign trust that was established 25 years ago by an Irish domiciled settlor. The settlor was non-resident for income tax purposes and is since deceased - the foreign trustee wishes to avail of the qualifying disclosure initiative. What steps should the trustee take in order to avail of the initiative?
The trustee should firstly deliver a Notice of Intention to Disclose by 1 September 2009 and also give brief details of the estate concerned and then make the Disclosure and Payment of undeclared liabilities by 31 October 2009.
Income tax and capital gains tax are owing by an Irish trustee in respect of assets settled on an Irish trust for the benefit of Irish resident beneficiaries. Can the trustee avail of the qualifying disclosure initiative?
Yes. The benefits of the current qualifying disclosure initiative apply in relation to undeclared tax liabilities by the trustee. Equally, beneficiaries with undeclared tax liabilities in relation to, say, disbursements made out of the trust can avail of the initiative.
Where a Will Trust exists and there are, say, undeclared Capital Acquisitions Tax liabilities can the qualifying disclosure initiative be availed of?
Yes. The benefits of an unprompted qualifying disclosure may apply – whether the Will Trust concerned is an Irish or foreign trust.
Can an employer that has set up a trust structure (whether Irish or foreign) avail of a qualifying disclosure in respect of tax issues arising from the transfer or settlement of assets or monies to / on such trusts or structures for the benefit of its employees?
Yes. The Revenue investigation will include an examination of cases involving the use of offshore trust structures for employees. Where an employer has tax issues in respect of assets or monies transferred to or settled on trusts or other structures, such as, employee benefit trusts, the employer may avail of the benefits of the qualifying disclosure initiative in respect of undeclared liabilities. The key dates for availing of a qualifying disclosure are 1 September 2009 [delivery of a Notice of Intention] and 31 October 2009 [making of Disclosure & Payment].
Where a proprietary director or an employee has tax issues in relation to funds or assets transferred or settled to / on a trust structure for their benefit by the company / employer, can a qualifying disclosure be made under the current initiative?
Yes. The Revenue investigation will be concerned with an examination of the use of trust structures, such as, employee benefit trusts and incentive plans. Taxpayers with tax liabilities arising in relation to funds or assets transferred to / or settled on such trust structures [whether Irish or foreign] can avail of the benefits of a qualifying disclosure.
Are undeclared liabilities relating to investments made in offshore collective investment schemes and unit trusts [Irish or foreign] within the scope of the qualifying disclosure initiative?
Yes. Persons with undeclared tax liabilities relating to offshore collective investment schemes or Unit Trusts can avail of the initiative.
An individual has an investment fund with a stockbroker [Irish or foreign] or financial intermediary [Irish or foreign]. The acquisitions and disposals of shares are made though nominee entities / trustees and there are undeclared tax liabilities over the years in respect of the fund / investments. Is this within the scope of the qualifying disclosure initiative?
Yes. Persons with undeclared tax liabilities in relation to investments or acquisitions & disposals of shares involving the use of nominee entities or trustees are within the scope of the initiative and can avail of a qualifying disclosure.
Is a person (including a company) with tax issues relating to the use of, say, an offshore company or structure which is used to meet foreign credit card payments within the scope of the qualifying disclosure initiative?
Yes. The focus of the Revenue investigation relates to the use of structures, such as, foundations, establishments, trust enterprises and offshore companies - hence, the qualifying disclosure initiative applies to tax issues relating to these entities.
An individual has transferred funds to an offshore nominee company and has not declared the underlying finds or the investment income for tax purposes - can the initiative be availed of?
Yes. The scope of the Revenue investigation will include an examination of transfers of funds and assets to trusts [Irish and foreign] and other offshore structures, as well as the profits and gains arising within, and disbursements made out of the structures. Taxpayers with taxation liabilities relating to funds transferred to an offshore company may avail of the benefits of the initiative.
Funds were transmitted to an offshore company for the benefit of an employee or director and neither the underlying funds nor the income and gains arising to the offshore company have been returned for tax purposes. Does the Initiative apply?
Yes. The Initiative can be availed of in relation to the undeclared liabilities arising.
Where an adviser or taxpayer feels that a meeting would be helpful in dealing with the taxation issues in complex or uncertain cases can a meeting with Revenue be arranged and what is the phone number?
A mutually convenient time and date for a meeting with a member of Revenue's Special Projects Team can be arranged by simply contacting the Revenue Helpline at 01-6329489 or 01-6329546. Revenue appreciate that the range of issues arising in trusts and similar type structures can at times be complex or varied – and time will be set aside to meet with and assist advisers and taxpayers.
Types of Trusts & Structures
The Revenue investigation is concerned with the tax treatment of property, assets and funds transferred to or settled on trusts [whether Irish or foreign] and on similar structures, such as, a foundation [stiftung], establishment [anstalt], trust enterprise and offshore company. The use of these structures in the transfer and settlement of assets and monies, and the accompanying tax risk, has come to light in the course of Revenue's earlier investigations. Also, the new Third Party reporting obligations which apply to offshore settlements made on or after 24 December 2003 means that Revenue will receive this information from mid 2009.
The legislation also allows a Revenue Authorised Officer to issue a notice to any person, where there is reason to believe that the person has information relating to a settlement, requiring the delivery of such information. Such a notice may apply to an Irish or foreign settlement made pre or post 24 December 2003.
What types of trusts and structures are included and does the qualifying disclosure initiative apply to the undeclared liabilities relating to these entities?
The scope of the Revenue investigation covers all categories of trusts (whether Irish or foreign) and special purpose vehiches, entities, arrangements, agreements or rights - including, but not limited to, trusts, trust enterprises, foundations [stiftung], establishments [anstalt], offshore companies, nominee entities, employee / director benefit trusts and incentive plans, investment schemes / funds and investment partnerships. The qualifying disclosure initiative applies to all undeclared liabilities relating to the trusts and offshore structures.
The funds transferred offshore are held in an establishment (anstalt) or foundation (stiftung). Are these included for qualifying disclosure purposes?
Yes. You may avail of qualifying disclosure in respect of undeclared liabilities in respect of these and similar structures.
Is undeclared Discretionary Trust Tax within the scope of the Qualifying Disclosure Initiative?
Yes. The qualifying disclosure rules apply. The Revenue investigation will also focus on cases with undeclared CAT liabilities.
What is the position as regards undeclared liabilities on Irish trust income & gains?
The Revenue investigation will examine the tax treatment of settlements made on Irish trusts & the tax position of the trust itself. Taxpayers including Irish trustees may avail of the benefits of a Qualifying Disclosure in respect of undeclared liabilities on Irish trust income and gains.
Does the qualifying disclosure initiative apply to tax issues relating to discretionary trusts and trusts created under a Will?
Yes. The qualifying disclosure initiative applies to undeclared liabilities relating to all categories and classifications of trusts.
Calculation Issues
Tax Computation
What is involved in the tax computation?
There are four elements to the computation - the undeclared money; the tax and PRSI/levies due on this money; the statutory interest due for late payment of the tax; and a "tax-geared" penalty.
How much do I owe?
The answer to that question will vary in every case. It depends on how much money is undeclared and under which "tax" type (Income Tax, VAT, Capital Gains Tax, Capital Acquisitions Tax, etc.) the source is chargeable. The longer it has been since you failed to declare the money, the more statutory interest will be payable. The circumstances of your case will also determine the penalty payable.
Will Revenue calculate the figures for me?
No. For a qualifying disclosure to be valid, the person making the disclosure must provide a full computation of tax, interest and penalty. Revenue staff will give assistance where possible by providing information about tax rates, rate bands, thresholds, etc. You may wish to consult a professional adviser to assist you.
What if I can't get full information about how much money I did not declare?
Where records are not available for earlier periods, estimates, which can be shown to be best estimates based on reasonable assumptions, should be used to ensure that liabilities are calculated, disclosed and paid by the 31 October 2009 deadline. Provided reasonable assumptions are used in the calculations, problems should not arise in the course of any future inspection by a Revenue auditor. Benefits will be retained as respects the disclosure made and as respects additional amounts, if any, to be paid in respect of adjustments and corrections. Calculation errors, which are not significant, will not invalidate the benefits of disclosure and payment.
Statutory Interest
What is "statutory interest"?
Statutory interest is charged for late payment of tax, PRSI and levies. Statutory interest runs from the due date for payment in each tax period until the tax is paid. For Income Tax, payment is due by the "preliminary tax" date; different dates will apply to the other taxes. The statutory interest is a percentage of the tax (plus PRSI/levies) underpaid. The Finance Act 2005 provides that all late payment interest rates in respect of tax (i.e. IT, CT and CGT) are calculated on the basis of a daily rate, including those rates that were previously expressed in terms of a monthly rate.
There is no "cap" on statutory interest.
| Period (inclusive dates) | Daily Interest Rate | Tax Head |
|---|---|---|
| From 01/11/1990 to 31/03/1998 | 0.041% | IT, CT, CGT, CAT, VAT |
| From 01/04/1998 to 31/03/2005 | 0.0322% | IT, CT, CGT, CAT, VAT |
| From 01/04/2005 to 30/06/2009 | 0.0273% | IT, CT, CGT, CAT |
| From 01/04/2005 to 30/06/2009 | 0.0322% | VAT |
| From 01/07/2009 | 0.0274% | VAT |
| From 01/07/2009 | 0.0219% | IT, CT, CGT, CAT |
Please note: "statutory interest" is the interest charged by Revenue.
My undeclared income goes back over 20 years. Do I have to pay 20 years' worth of statutory interest?
Revenue is extending the practice used in dealing with Interest Reporting - DIRT-liable Account holders to allow that income arising in years up to 1997/98 may be treated as income of that year. If the income was earned in 1980, for example, you can treat it as income of 1997/98, calculate the tax due on that income, and pay statutory interest on the unpaid tax at the rate applying to 1997/98. NB - you can also choose to tax the money at the tax rates and bands applying in 1980, for example, but the statutory interest will run from 1997/98.
Penalty
What is the "penalty" payable?
The penalty is described as "tax-geared" because it is not a fixed penalty, but a percentage of the tax (plus PRSI/levies) underpaid. There is no "cap" on the penalty.
What percentage of the tax will the penalty be?
If the tax default arose in a period ending on or before 5 April 1991 - that is, up to the tax year 1990/91 - by law, the penalty for underpaid tax cannot be mitigated. In those periods, therefore, the penalty is 100% of the tax due. After that, the penalty can be mitigated for co-operation and for making a qualifying disclosure, depending on the type of tax default involved. In the circumstances of these disclosures the rate of the penalty is 10%. However, where income or gains arose prior to 5 April 1991 the income or gain will be assessed by reference to the rates pertaining in 1997/98 but the penalty will be 100% of the tax owing.
In the case of the estate of deceased persons there will be no penalty, unless there was a binding agreement with the deceased before death, only the tax and statutory interest are payable.
Payment
How do I work out the total amount due?
To get the total you add the tax, statutory interest and penalty together, remembering to convert from Irish Pounds into euros, where necessary.
How do I pay what I owe?
You may submit a bank draft or cheque made payable to the Revenue Commissioners.
What if I can't pay the liability in full?
You must make a full disclosure, and give a full account of your circumstances, including ALL your assets and liabilities
In these circumstances, the form should be submitted well in advance of the 31 October 2009 deadline, so that Revenue has an opportunity to consider whether you are unable to pay the full liability as calculated.
You should also make a payment on account - that is, pay a substantial portion of your liability. If you do, the rate of statutory interest will be fixed at the date the payment is received. If you do not make a payment on account, the rate of statutory interest will continue to rise on a daily basis until you do. You should explore options for paying the balance of the money. Where the extent of your ability to pay and the payment to be made are agreed and the agreed payment is made the treatment outlined in this Initiative will be applied.The same requirements will apply where the inability to pay relates to liabilities in respect of which an executor or administrator is assessable in respect of the estate of a deceased settlor.
Declaration
What kind of declaration is required?
You should make a declaration in the following terms:
"I declare that, to the best of my knowledge, information and belief, all statements I have made in this disclosure are correct and complete."
Where do I send the Notice of Intention to Disclose?
Please send it by 1 September 2009 to:
Office of the Revenue Commissioners
Investigations and Prosecutions Division
Special Projects Team
5th Floor
Lansdowne House
Lansdowne Road
Ballsbridge
Dublin 4
Where do I send the Statement of Disclosure?
Please send it to the same address to which you sent the "Notice of Intention to Make a Qualifying Disclosure" to arrive by 31 October 2009:
Office of the Revenue Commissioners
Investigations and Prosecutions Division
Special Projects Team
5th Floor, Lansdowne House
Lansdowne Road
Ballsbridge
Dublin 4
A Revenue Helpline is available at:
01- 6329489 and 01- 6329546, Monday to Friday, 8.30 a.m. to 4.30 p.m.
After Making a Disclosure
What happens once I submit my statement of disclosure?
On receipt of the disclosure and payment an acknowledgement will issue to yourself or your tax adviser.
What if I've made a mistake in my disclosure, or if I've under-estimated the tax, interest and penalty due?
If you've underestimated the amount payable, you will be liable to pay the balance - the additional tax, statutory interest and penalty. The percentage rates of statutory interest and penalty will stay the same, but the amounts will be higher because they will be based on a higher amount of tax.
If you would like any questions added to the above list please e-mail your question using the following link specialprojects@revenue.ie
Last Updated: June 2009