Important reminder of disclosure opportunity to regularise misclassification of self-employment

On 15/01/2025, Revenue reminded businesses that they have an opportunity to correct payroll tax issues for 2024 and 2025, arising from bona-fide classification errors, without the imposition of interest and penalties.

In order to avail of this opportunity, and have the correction treated under the Code of Practice for Revenue Compliance Interventions, businesses are required to:

• submit a disclosure by 5pm on Friday 30 January 2026, and 
• pay all related liabilities in full via REVPAY, or request a Phased Payment Arrangement (PPA) to pay the liabilities, when submitting their disclosure.

Revenue announced this disclosure opportunity in early September 2025, recognising that some businesses may have experienced genuine difficulties in making the necessary payroll adjustments following the landmark decision delivered in Supreme Court judgment in The Revenue Commissioners v Karshan (Midlands) Ltd t/a Domino’s Pizza.

The disclosure opportunity gives businesses that may have misclassified employees as contractors the chance to make a disclosure in respect of payroll tax errors in 2024 and 2025. Full details of the disclosure opportunity are set out in Revenue Guidelines – ‘Settlement arrangement arising from Revenue v Karshan (Midlands) Ltd. trading as Domino’s Pizza’.

Revenue is aware that some businesses that are reviewing the status of employees/contractors are concerned that they will not have fully completed the review by the 30 January deadline. 

Revenue would like to clarify to those businesses who are preparing disclosures that if, after the submission deadline, there is a need to amend the details of a disclosure which has already been submitted, Revenue will accept those amendments in accordance with the Code of Practice for Revenue Compliance Interventions, provided that:

• the original disclosure was made on a best-efforts basis, 
• the amendments do not arise from careless or deliberate behaviour, 
• the amendments are not material in nature,
• the declared liability is paid or a PPA is requested, and critically,
• employees who work for the business are properly classified and PAYE/PRSI is being operated through the PAYE system for 2026. 

In such cases, Revenue will continue to regard the disclosure as qualifying. 

[ENDS 15/01/2025]