New Code of Practice for Revenue Compliance Interventions

Revenue eBrief No. 031/22

New Code of Practice for Revenue Compliance Interventions

Revenue has published its new Code of Practice for Revenue Compliance Interventions which will come into effect on May 1 2022 and will apply to all compliance interventions notified on or after that date.  

This Code sets out details of Revenue’s revised framework of compliance interventions. This framework provides for a consistent, graduated response to taxpayer compliance behaviour ranging from easily accessible opportunities to voluntarily correct errors up to criminal investigation for serious cases of fraud or evasion.

The revised Code is being published at this time to facilitate preparation for the changes. The existing Code of Practice for Revenue Audits and other Compliance Interventionswill continue to apply to all interventions currently open and any further interventions notified prior to 1 May 2022.


1. Introduction
Revenue’s Mission is to serve the community by fairly and efficiently collecting taxes and duties and implementing customs controls. We achieve this by providing excellent service to support voluntary compliance and delivering a risk-focused, effective, and proportionate response to non-compliance that reflects taxpayer behaviour.

It is the responsibility of every taxpayer to comply with their tax and duty obligations. We recognise and appreciate that most taxpayers voluntarily and diligently discharge this responsibility and we aim to minimise the burden of tax compliance for them. We do, however, recognise that taxpayers may on occasion, make mistakes in their tax affairs and we provide extensive facilities to enable taxpayers to voluntarily address errors and make good any liabilities with minimum penalties. We must also recognise that a minority will actively seek to evade or avoid their liabilities and we must respond in an appropriately robust manner in these cases to uphold the integrity of our tax system.

This Code of Practice, which comes into effect on 1 May 2022, sets out a Compliance Intervention Framework intended to provide a consistent graduated response to taxpayer behaviour, ranging from extensive opportunities to voluntarily correct mistakes up to the pursuit of criminal sanctions for cases of serious fraud or evasion. The different ‘intervention levels’ within the framework are set out in this Code.

This framework of interventions will further enhance our real-time engagement with taxpayers using the insights from PAYE Modernisation to expand real-time compliance management of our segmented case-base while incorporating our traditional tax audit approach within a Compliance Intervention Framework that provides a graduated response to risk.

This Code of Practice sets out what you, as a taxpayer, can expect from Revenue if we contact you in relation to your tax affairs and how we will conduct our interventions. It also sets out the benefits that arise from disclosing any default at the earliest opportunity and cooperating fully with a Revenue inquiry. The Code provides details of how and when penalties apply for different categories of default and sets out your entitlement to Review or Appeal if you are dissatisfied with either the conduct or outcome of a Revenue Compliance Intervention.

The Code is intended to provide you with certainty and clarity around the opportunities available to review your tax compliance position and to voluntarily address any issues identified. Taxpayers who avail of these opportunities will experience the minimum level of penalty and generally not risk either publication or prosecution. Revenue will progressively respond with appropriate vigour to taxpayers who do not comply voluntarily or change the behaviour leading to tax non-compliance. Where serious tax or duty evasion or fraud is identified during the course of any compliance intervention (regardless of intervention level), Revenue will initiate an investigation with a view to prosecution as set out in Chapter 6 of this Code.