Co-operative compliance

Drawing up an action plan

The action plan drawn up by participants in the Co-operative Compliance Framework (CCF) and Revenue will lead to:

  • a programme of annual risk review meetings
  • voluntary disclosure of any issues that arise
  • clarification regarding the interpretation of tax law
  • and
  • consistent application of tax law across all business sectors.

Revenue and your business will draw up, and agree on, the action plan. The plan will include a set of action points for each side to complete within the time frames decided.

The aim of the plan is to:

  • fully review the tax risk for the business
  • and
  • carry out any compliance actions needed for each tax type.

Highlighting risk areas

An annual risk review meeting will be held with each CCF participant Group. Revenue will highlight tax risk areas for your business and you can request clarity on particular concerns you may have. At the end of the meeting, there should be agreement on the initial tax risk profile for your business. You will prepare and complete annual tax risk management plans that focus on the agreed risk areas.


Revenue interventions will, where necessary, be a part of the overall action plan. We will make you aware of planned interventions. If your business genuinely engages in co-operative compliance, Revenue interventions will be as non-intrusive as possible. Risk analysis driven by profiling and business intelligence will continue for all businesses.

We may carry out audits or investigations outside those highlighted in the co-operative compliance plan, in particular, Transfer Pricing audits.

A Group can make an unprompted disclosure if it becomes aware of an issue during compliance reviews. See the Code of Practice for Revenue Audit and other Compliance Interventions for detailed information about unprompted disclosures. If you have already received an audit letter from us, the rules for prompted disclosures will apply.

Tax planning

Revenue recognises that legitimate tax planning is an important part of financial management for businesses. We expect businesses that engage in co-operative compliance will be open with their tax planning strategies.

Communication with Revenue

Revenue will respond as quickly as possible when you ask for help in interpreting tax law. Ideally, the help from us will take the form of consultation at the earliest possible stage.

You may submit complaints to us about tax-based competitive advantages that your competitors enjoy, which you feel are unfair. We will quickly respond to any well-founded complaint of this kind.

Next: Monitoring the effectiveness of co-operative compliance