Revenue eBrief No. 041/26

02 March 2026

Expression of Doubt - Full Self-Assessment

Tax and Duty Manual (TDM) Part 41A-03-00 - Expression of Doubt - Full Self-Assessment - has been updated with the insertion of a new paragraph 6 which states that the extended due date which applies where a taxpayer has made a genuine Expression of Doubt only applies to the matter about which doubt has been expressed.  Section 959AU(3) Taxes Consolidation Act 1997 (TCA), introduced by Finance Act 2025, provides that the due date for the payment of tax is to be determined in isolation on a second or subsequent assessment - in such cases the tax due and payable does not benefit from the extended due date in section 959AU(2) TCA and reverts to the original due date.

Paragraph 4 contains material previously in a footnote which outlines that Expressions of Doubt do not apply where a chargeable person is uncertain whether a person they engage is employed or self-employed.