Revenue eBrief No. 177/22

26 September 2022

Guidance on the Level 1 Compliance Programme – Debt Warehouse Scheme

Revenue has published a new Tax and Duty Manual – Guidance on the Level 1 Compliance Programme - Debt Warehouse

In September 2022, Revenue issued a Level 1 Compliance Intervention notification offering taxpayers an opportunity to self-review returns eligible for debt warehousing and, if additional undisclosed relevant liabilities arise, these can benefit from the provisions of the DWS.  By making an Unprompted Qualifying Disclosure in relation to previously undisclosed Period 1 liabilities on or before 31 January 2023, the taxpayer has an opportunity to have those additional liabilities warehoused under the terms of the DWS.

A taxpayer who makes an Unprompted Qualifying Disclosure also receives the normal benefits of mitigation of the tax-geared penalty (in cases where such a penalty applies), non-publication of the tax settlement and non-prosecution.

Detailed information regarding the compliance programme and the opportunity to disclose additional liabilities is outlined in this Tax and Duty Manual.