The new Code of Practice for Revenue Compliance Interventions has been published by Revenue and sets out a revised framework of compliance interventions. The Code will take effect from 1 May 2022, and will apply to all compliance interventions from that date. Substantial changes have been made to Revenue’s approach to compliance interventions and disclosure opportunities and the issuance of ‘aspect queries’ will cease from 1 May 2022.

The new code, which replaces the current Code of Practice for Revenue Audits and other Compliance Interventions 2019, reflects a graduated response to risk and taxpayer behaviour. The graduated interventions are Level 1, 2, and 3.

  • Level 1 is considered an intervention to support compliance, i.e., self-reviews, profile interviews, bulk-issue non-filer reminders, etc. The taxpayer retains the right to an unprompted disclosure.
  • Level 2 is a risk review audit. This is an intervention to challenge non-compliance and the taxpayer retains the right to a prompted disclosure.
  • Level 3 is an investigation and at this point a qualifying disclosure is no longer available to the taxpayer.

The code will cover all taxes and duties with the exception of customs.