Revenue eBrief No. 172/25
11 September 2025
Karshan Disclosure Opportunity Guidance
A new Tax and Duty Manual (TDM), Karshan Disclosure Opportunity Guidance has been published to provide guidance on the settlement arrangements arising from the Supreme Court decision in October 2023 in the case of ‘The Revenue Commissioners v Karshan (Midlands) Ltd. trading as Domino’s Pizza. The judgment provided employers with further clarity regarding the correct approach to employment classification for tax purposes.
Revenue recognises that employers may have faced difficulties in making the necessary adjustments to their payroll systems. Revenue is now providing employers with an opportunity to correct any payroll tax issues in respect of 2024 and 2025 arising from bona-fide classification errors.
Detailed information regarding the settlement terms is set out in this Tax and Duty Manual.