A new analysis of Revenue data provides fresh insights into the approach of the Irish tax authority on endorsements, audit activity and avoidance priorities.

The analysis, based on statistics prepared by Revenue over the three-year period between January 2022 and December 2024, highlights the gradual scaling up of Revenue debt activity after it shuttered its audit and enforcement activities during the pandemic.

It also outlines the impact that the expiry of the authority’s Covid debt warehouse, where businesses could freeze tax liabilities accumulated during pandemic restrictions, has had on the number of firms and individuals agreeing to phased payment plans with the tax authority.

The analysis, which compares headline results published by Revenue in each of the last three years, provides evidence that the authority is working its way through the Covid backlog of debt cases, although its level of official activity still remains below pre-pandemic rates.

One of the areas that has seen a noticeable surge in activity relates to Revenue’s targeting of tax-avoidance schemes. 

In 2024, Revenue settled tax-avoidance cases with 256 taxpayers, more than the previous two years combined. Many of these cases had been going on for a number of years and were waiting for adjudications from the Tax Appeals Commission.

For example, the tax authority successfully targeted 70 well-heeled investors who sought to reduce their tax bills by investing in a complex €200 million offshore property fund, details of which have been previously reported on by The Currency.

The yield from the various settlements has also spiked, rising from €16.1 million in 2022 to €46 million last year. Despite closing a large swathe of cases, the authority is still challenging a further 228 tax-avoidance cases, relating to 22 transactions involving 261 appeals.

There has also been a spike in the number of debt enforcement actions taken by the Revenue. The chart below contains the number of actions taken by the authority through the Revenue sheriff, the Revenue solicitor and through attachment orders. 

According to Revenue briefing notes, solicitor enforcement is one method available to Revenue where there is no meaningful engagement by a business or individual to resolve outstanding tax debts. This is the process by which Revenue commences enforcement action through the courts. “Not all solicitor referrals will result in High Court action as many cases are resolved before the case proceeds to court,” according to Revenue.

Other enforcement options available to Revenue include sheriff referrals and attachments. Sheriffs are officers of the court, appointed by the Government to carry out debt collection for Revenue.

Attachment, meanwhile, is an enforcement method whereby Revenue may attach a third party, or an employer, where there is a tax debt due to Revenue. Some of the attachee's payments to the taxpayer may then flow directly to the authority.

The rise in enforcement activity has led to a corresponding rise in the related yield, with the figure increasing to €229.1 million last year, according to the Revenue data.

Full enforcement activity typically comes after an initial compliance and audit intervention. Figures show that the number of such interventions rose year-on-year in 2024 but was down on 2022 levels. 

Likewise, the yield from such interventions has also decreased in recent years. This is likely explained by the greater targeting by Revenue of specific companies, issues or sectors. With increased modelling, the authority is able to utilise its audit resources in more targeted ways. 

The analysis of Revenue data also shows that the number of individuals or companies who have entered into phased payment agreements with the tax authority has remained broadly in line over the three-year window under review if the figures for the debt warehouse are excluded.

However, if former warehouse recipients are included, there has been a surge in the numbers with Revenue agreeing on a large number of bespoke deals in 2024 as the warehouse ended. 

The authority said in recent days that at least €100 million in warehoused debt from a scheme introduced to help businesses during the height of the Covid-19 pandemic is not recoverable. 

Some €3 billion of the €3.2 billion included in the warehouse at its peak in January 2022 has now been either settled or secured under a phased payment arrangement.

Further reading

Yields, litigation, and attachment orders: Five graphs that explain Revenue enforcement strategy