In mid-March, as the scale of the crisis was becoming manifest, Niall Cody placed a call with the Department of Finance. The government had implemented a rapid-fire Covid unemployment benefit, administered by the Department of Social Protection, but it was becoming obvious that something greater was required to help keep people in jobs. 

As chairman of the Revenue Commissioners, it is Cody’s job to collect taxes. But he also knew that the real-time reporting tools his organisation had developed could be used to pay money out. So, he rang the Department of Finance and offered to help.

Within days, the Temporary Wage Support Scheme (TWSS), a key plank of the state’s efforts to help those businesses worst impacted by the crisis was enacted. To date, the authority has paid out €1.8 billion on behalf of the state, helping 410,000 workers and 64,000 employers.

The UK government announced a variant of the scheme before Ireland did, but the project took more than a month to get going. The Irish version was legislated for and fully operational within a week. 

“We published a new statement of strategy at the end of last year,” Cody says. “And paying out €1.8 billion certainly was not part of it. My colleagues across the civil service are laughing at the tax collector paying out money. But we see ourselves as a huge part of the infrastructure of the state, and we were able to help.” 

Administering the scheme has not been the only thing that Cody did not expect to be doing. Since the crisis, all enforcement activity has been halted. Following engagement with government, Revenue has also allowed struggling businesses the opportunity to defer tax payments for up a year. Almost €2 billion in tax has now been warehoused, he says. 

However, Covid-19 is not the only big-ticket item on Cody’s radar. A no-deal Brexit looks likely, and, as part of its contingency planning, the authority has been engaging with more than 100,000 businesses and planning for any potential outcome.

Meanwhile, the clamour for international tax reform grows louder still, with an increasing number of countries such as France and Germany looking for a greater share of the global tax pie. The government has acknowledged that any changes will be to the detriment of Ireland. 

Cody is not involved in the politics of the ongoing negotiations, but his role is to work with the Irish government and provide technical advice.

Within government, the Revenue Commissioners has long been regarded as among the most able state bodies. Given the scale, scope and import of issues it is now dealing with, this is just as well. 

*****

We meet in the boardroom of the Revenue’s headquarters in the upper yard of Dublin Castle. 

The building has been shut down since the start of the crisis, but Cody has been turning up to the office most days. 

Some 6,000 of Revenue’s 7,000 staff have been working remotely, with the remaining 1,000 required to physically man ports and airports. Some 70 Revenue staff are remotely running the helpline for the TWSS, while others have helped the HSE with contact tracing. 

It has been, he says, “the biggest pilot remote working experiment ever”.

The interview has been arranged following the publication of Revenue’s annual report, which included a wealth of new information about everything from PAYE trends to onshoring of intangible assets by multinationals. 

Cody has brought the various reports and briefing material with him. However, over the course of a lengthy interview, he barely looks at them, speaking fluently and authoritatively across a wide range of subjects. 

Appearing at various Oireachtas committees, Cody can sometimes appear prickly and tough, which, as head of the national tax authority, is arguably not a bad thing. In person, however, the career public servant is polite, understated, and thoughtful. 

We begin by talking about the Revenue’s response to the crisis.

Ian Kehoe (IK): Audit activity ceased obviously. Do you think that will lead to an increase in non-compliance? When do you think it may be possible to resume?

Niall Cody (NC): While the outdoor piece of it has ceased, we have open interventions with business. They continue over a period, some are continuing with taxpayers and their agents and we are probably getting back to a level of normality to try and finalise those interventions. 

But the environment has changed considerably as well. So, we’ve gone from a position where businesses have been trading very successfully to not trading at all and the tax compliance issues around 2020 will be very different because a lot of businesses won’t have tax liability. So, we will continue to look at how we best re-engineer the process and get back as soon as it’s safe and normal. 

But it is really interesting to see what’s happening across the world in tax administration. We play an active part in the forum on tax administration in the OECD and actually, this morning I was looking at presentations that were made by our Norwegian and US/IRS colleagues around workplace and the challenge facing them. And those are challenges we also face. I think we’re going to see fairly significant changes over the next period around how we engage with business – building on things like real-time systems, PAYE obviously is the biggest, and using our data analytics and real-time tax compliance systems. All this is going to see a shift over the next couple of years. I think what has happened is that this is just accelerated a trend which will lead to differences and different challenges for business and, I think, also different challenges for the tax agents and practitioners. It’ll be a different system for them and a challenge in the business models in that area.

IK: I know you were centrally involved in devising the Temporary Wage Subsidy Scheme. It must have been a DNA shift for Revenue to go from taking money to giving it out. But I suppose it’s developing a different relationship with people as well. 

NC: The thing that really stuck us early was that this was going to have a devastating impact on business and on employment. And we see ourselves as being a huge part of the infrastructure of the state and our role is to facilitate and support businesses. We knew if we could do something, we should do it. Before the crisis, I never anticipated that we would be paying out €1.8 billion. 

I didn’t anticipate that we would be suspending enforcement activity, that we wouldn’t be charging interest, that we would have a debt warehousing system.

“I think that is why maybe some businesses haven’t gone looking for loans in the short-term – because here is a practical measure which is zero-rate interest.”

Niall Cody

IK: I know the scheme was introduced quickly and much of it is based on self-assessment. Do you think it may have been abused, that you will have to start clawing back money?

NC: It is structured in such a way where the opportunities for fraud are very limited. It is designed in a way to build on real-time reporting by compliant taxpayers and all the conditionality was put in based on employees being on the payroll on February 29, compliance with reporting by March 15, which ties in with the PAYE reporting requirements. A number of commentators talk about these as arbitrary figures. These are actually dates that are set out in the PAYE legislation. So, if you have a record of compliance with payroll reporting and the employees are all on your books, I don’t see that businesses are going to turn into an opportunity to defraud the State in the midst of a crisis. 

And it was structured in a way to allow us to pay up the money immediately, which was a huge support to business. Our colleagues in the UK announced their furlough, which is a different type of scheme. But they announced it before we announced ours and didn’t pay out anything until the end of April. 

I see even in today’s paper about our assurance programme, which we are going to do. I think some of the commentary by some of the practitioners is a bit odd in that what we’re trying to assure is that employers are operating properly and, most importantly, that the employees are getting what they should be getting. 

And I know we issued our press release on the programme and people interpret that we’re sending out 64,000 letters starting today. This is a process that’s going to take place over the next couple of months and really it is to assure ourselves and to assure employees that it’s being done properly because there are certain conditions. Employers are supposed to show the subsidy on the payslips. They’re supposed to issue payslips under employment law. 

While we will be engaging with all employers in receipt of it, we actually expect that once we get a reply, that there’ll be no need for follow up for most of those cases. I suppose one of the things that’s inherent in the system as well is that as you are probably aware there were two phases. There was the initial phase in which we paid €410 for every employee. That is an inherent overpayment because we knew everybody wouldn’t be entitled to €410. So, every employer got that and then from May 3, the operational phase applies. So, there is an inherent overpayment and the Government made that decision that better do that that way and obviously at the end of it, the process will be balancing all those arrangements.

IK: The other big thing is the debt warehousing. Are you confident of being able to recoup the money from businesses?

NC: On March 15, we first said if you’re a business and you’re having difficulty, file returns and then contact us. Very quickly we actually changed our arrangement and we said if you’re a small or medium business dealt with by our business division, you effectively file your return and we will be suspending enforcement activity and interest activity. And if you’re a larger case or dealt with our medium enterprise division and you’re having difficulty, talk to us and you’ll be able to essentially park your liability. 

The Department of Finance and ourselves were looking at the situation, where businesses were going to have this difficulty. So, the proposal then came up to effectively warehouse the debt that is Covid-related and looking at the idea and proposals around a zero-rate interest rate for a year in addition to the warehouse, for the warehouse debt. And then a reduced rate of 3 per cent for the period until it is paid back. 

Obviously some of the debt, like any debt, won’t be collected but I think that as a support – and we all hear about the importance of the cash flow and liquidity – I think that it is a practical support to businesses. 

At the end of May, there was €1.5 billion debt warehoused. Interesting, and we published last week a report on the debt warehousing, there was a significant amount of debt that was parked in March that has subsequently been paid. We anticipated by the end of June there’d be about €2 billion in the warehouse. I think it probably will be a bit less than that. But from the middle of March to date, over €400 million of the debt that was warehoused has subsequently been paid, which I think is really interesting. 

I listen to too much news. I listen to too much commentary. But I was listening today about people who lobby or always extenuate the negative and they were talking about the lack of support for SME’s. Here is a real practical support and I think that is why maybe some businesses haven’t gone looking for loans in the short-term – because here is a practical measure which is zero-rate interest. 

I think that a lot of businesses at the start were being prudent. They didn’t know what was going to happen and were now in a position to pay it.

IK: If you take the fact that so much has already been repaid, and you look at the fact that the tax take has held up reasonably well, it is a positive picture. 

NC: In conjunction with the annual report we published a lot of reports. I know that obviously corporation tax is interesting and I presume we’ll talk about that. But the two reports I think are most interesting were our PAYE information for June 2020, when we looked at the five months. We looked at the idea of the level of gross pay, the impact of the PUP and the Wage Subsidy and it’s actually really interesting the amount of money that has stayed in the system. The supports like the PUP [the Pandemic Unemployment Payment] and the wage subsidy scheme for May meant that net pay was nearly €6.4 billion. In January net pay was €6.5 billion. Now I know there’s a tax issue around the PUP and the Wage Subsidy but that is a later issue. 

And I think on page seven on the report we have the analysis of the labour market churn. We still created the same level of new jobs during the period, but I know just that there was a whole load of jobs that were lost. But the jobs that were created again were effectively higher paid jobs and I suppose reflects the idea as well that there are probably sectors that are going flat out.

But if we take the debt that we’ve warehoused on top of the tax that is paid, we’re probably running at last year’s figures, which is phenomenal. Now, it does show that the sectors that were really significantly impacted were the sectors that tend to be lower paid whether it’s retail, hospitality, accommodation. There have certainly been challenges in particular sectors and younger people and a lot of casual type work has gone and part-time work has gone. I think it’ll be interesting to see how that unfolds as sectors open up again

*****

An island at the centre of the (tax) world

The international tax landscape is changing; led by the OECD, the weight of international opinion is for a rebalancing of how multinationals pay tax – and in what jurisdiction they pay it. 

Ireland has straddled the debate, working with the OECD but attempting to ensure Ireland is not overly impacted. Within government, there is a broad acceptance that any changes to the current rules will lead to a decrease in corporation tax in Ireland – an area that has swelled in recent years.

The politics and parlour games of the negotiations are not part of Cody’s remit. But, as chairman of the Revenue Commissioners, he is an authoritative voice on the importance of the multinational tax take here. 

Some 19 per cent of all tax now comes from corporates, with foreign multinationals advancing some 77 per cent of that figure. Data released last week by the Revenue shows that the top ten companies paid 40 per cent of all corporation tax and the top 100 paid 70 per cent. 

The reliance on such a small number of firms for such a large amount of tax has led to a considerable debate about the sustainability of the figure, particular given the international jostling by countries such as the US, France and Germany. 

Another major trend in recent years has been the onshoring of intangible assets, something that The Currency has reported on extensively. New data shows that multinationals claimed €45 billion in intangible assets last year, a rise of 98 per cent. 

Much of this money is routed through complex international structures, and this is also something that Cody is obliged to police.

IK: The corporation tax take has gone up and up – €10.8 billion last year.  This has raised an awful lot of questions about sustainability – even the finance minister has said it is likely to reduce. I know you had a report on it as part of your annual report. What’s your own view?

NC: Over the last five years, we’ve published increasingly detailed reports on corporation tax. I was appointed chairman in February 2015. The following November I was writing to the minister explaining, as we saw it, the impact of corporation tax. We then followed it up in April 2016 with a detailed report, and this is the latest of the detailed reports. They’re really interesting and they reflect very, very strong kind of economic growth, profitability and it’s clear that the figures speak for themselves. Forty per cent of it is made by the top 10 companies and that has stayed fairly constant over a number of years. The foreign direct investment companies pay a significant portion. 

We support the Department of Finance in technical work and technical analysis and last year we would have done our work based on our data, which suggested that it could be anything, depending on what happens with the international tax, anything between €500 million to €2 billion impact. 

“The core for us is to ensure that activity in Ireland, as taxable in Ireland, is taxed in Ireland.”

Niall Cody

Clearly, what happens in the international tax agenda is not clear – what the final outcome will be, depending on pillar one and pillar two, and then the elements of each of them. It’s an extremely complex arrangement. But I think it’s prudent for the minister and the Government to take a cautious view on how sustainable it is.

To me, the most interesting table shows that the top ten in 2015 they paid 41 per cent. In 2019, those ten companies paid 25 per cent. So, there’s a bit of flexibility and churn in the top ten as individual sectors increase. It changes. 

IK: How much of your effort goes into dealing with that top ten, that top 20? We did an exercise where we tried to map out the multinational structures of some of the biggest companies. It’s incredibly complex and we’re only doing it at a very high level. 

NC: Our job and our role is to ensure as best as possible that the right tax is paid by the right taxpayers and at the right time. And it’s the right Irish tax on the right Irish profits. And while the entities fit into a wider multinational, multi-country structure, the core for us is to ensure that activity in Ireland, as taxable in Ireland, is taxed in Ireland. 

That’s not to say that you can disregard the wider structure. In this year’s report, for the first time, we have an overview of the country-by-country reporting data, a high-level overview of that. Increasingly, the focus is on intercountry discussions around the proper attribution of tax. This is the role of the competent authority; around multinational, international disputes around profit attribution. So, in the last six years, we have significantly increased our resources both as a competent authority, in transfer pricing and there’s a kind of weighing scales. We have to invest in the competent authority to support the allocation of profits by multinationals to Ireland and we have to balance that with scrutiny to ensure that the profits that are attributed to Ireland are appropriate on the transfer pricing side. 

So, we have, in the realignment of our organisation from 2015 on, significantly increased our resources in the large corporate division. We have realigned to split large corporates and HWI [high net worth individuals]; it’s just too big of a job. 

We’ve increased our resources looking at that sector by well over 50 per cent and we’re going to continue investing in that. In a way the transfer pricing legislation went into the 2010 Finance Act and now we have two principal officer-led teams in large corporates looking at it. We’ve two principal officer-led teams in the competent authority. That’s a phenomenal investment in that area.

IK: The increase in corporation tax puts the attention on Ireland. How do you think our reputation has held up?

NC: If I go back to 2013, Ireland had the presidency of the EU. And on the tax front, we were looking at the tax agenda in say October, November 2012, and, by and large we were looking at an indirect tax agenda. There were some very important things that we felt we could advance and in March 2013 the whole world changed in relation to tax and corporation tax, the BEPS project. The OECD and the EU in parallel – some might say in competition – started advancing the whole base erosion and profit shifting. 

In 2015, then, we set up our international tax division because obviously Ireland figures prominently in the whole international tax agenda. So, what we decided to do is to be represented on every working group on the BEPS project. So, we support the Department of Finance. Generally, our role in international tax work is the detailed technical slog. 

IK: And not the politics. 

NC: And not the politics. But we support the policymakers because as you say in your analysis of some of the structures and the rules and the understanding of the legislation in the other countries, this is not for the faint-hearted. 

And so, what Ireland has done is to be a full participant in all the working groups at OECD level. From a reputational point of view, where we do have a role is meeting all our obligations on transparency, fulfilling all our requirements on meeting mutual assistance requests from other administrations. And in all the peer-reviewed studies of the Irish tax administration, we have been fully compliant. We have got the most compliant rating that you can get and that is a huge part of ensuring our reputation as a country. 

IK: There’s been a monumental amount of IP onshoring onto Ireland with massive numbers. How do you think that’s going to play out?

NC: I think the reality is the figures are the figures and in a way, all this is part of the result of the whole base erosion on profit shifting and that’s the moving of assets linked to presence and substance. Obviously, it’s part of that whole multinational agenda, the idea of how the tax system will evolve over time. It has moved at a phenomenal pace in tax administration terms and I think that will continue to evolve and we’ll have to respond.

*****

Avoidance, probes and the professional classes

Operating below the Large Cases Division, the Medium Enterprises Division (MED) has, since 2018, been monitoring the tax affairs of 16,000 individuals and entities. The criteria for inclusion is based largely on business interests, with the list including individuals whose businesses employ more than 100 people or generate revenues of more than €3 million.

The MED was also charged with assessing the professional classes, and partners of accountancy and law firms who have more than €3 million in annual fees are included on the list.

The partners of the Big Four accountancy and the five largest law firms are included as high wealth individuals within MED, but the division also looks at hundreds of other accountants and lawyers around the country as part of its operations.

Slowly, surely, the tax authority has begun to unpick many of the schemes being used by companies and professionals to minimise tax. The structures used by hundreds of locum doctors have been challenged, as have the use of service companies by both law firms and, on a larger scale, accountancy firms.  

In the past, there was no public record of many of these battles. However, the advent of the Tax Appeals Commission (TAC) changed this, bringing more transparency to the disputed tax cases. The names of the taxpayers are not made public in the commission, but it has provided more openness on the issues at play. 

IK:  I want to talk about the restructure within Revenue towards the medium enterprise division, As a result, you have a lot more visibility on companies and people operating below the super-wealthy or the super big. What was the rationale for that and how has it worked out?

NC: We restructured our organisation in 2003 when we moved from a functional model where audit was there, service was there, and so on, to essentially a regional structure and a large cases division. That was in 2003 and the core of that restructuring was about a focus on the taxpayer where one person or one office would have responsibility. I was heavily involved in the 2003 restructuring and we used to talk at the time that in probably in about ten years’ time we’ll be revisiting this again. 

Then the economy collapsed. So from about 2015, we started looking at our structure, looking at having to invest more resources in international tax and other areas. In each of the regions, we set up a second tier. This was what grew into the medium enterprise division, to have a dedicated resource in the regions looking at that tier below large corporates. Then that evolved into the realignment that we had in 2017, where we moved from the four regions and the LED to five operational divisions; large corporates, high wealth individuals, medium enterprises, business division and personal division. 

And what we did then was to try and increase resources to look at large corporates, HWIs and medium enterprises so that you have a dedicated resource. So, we get a greater understanding of what’s happening. 

I pay great attention to The Currency’s reporting. I have to commend your coverage of the determinations of the Tax Appeals Commission because to me that’s one of the most important reforms in tax administration over the last number of years. 

And I think there’s a wealth of information in those determinations of what is happening in the business world and I read with interest your coverage. The only thing that I think every so often – I kind of sit up a little bit, it’s kind of a little bit treated slightly as if it’s a sport and that there’s a winner and a looser. 

IK: Well there’s a determination. 

NC: Yeah, yeah, there’s a determination. But we don’t necessarily always see it as ‘oh we lost there’ because sometimes determination brings great clarity into what the rules are. 

When we set up the second tier in the regions, one of the first things we did was we put the professionals in the second tier, based in Cork at the time. And that grew into the band that is in medium enterprise. So, they were probably there a little bit earlier than some of the other sectors in medium enterprise. 

But it is not really all about tax in dispute or tax disagreements. It’s to increase our understanding of what’s happening in the various sectors. It equally applies to areas like how personal division deals with PAYE taxpayers but it’s looking at them from a national perspective and allows us to improve service. 

“Our compliance activity is staying constant even though the gross amount is going up. I think that’s really important.”

Niall Cody

IK: Obviously there has been a bit of a focus on professionals. Just from going through the TAC decisions, a lot of them seem to centre on the use of service companies. Is that kind of a key focus?

NC: The nature of the use of corporate structures – obviously, there’s differentiation between the corporate tax rate and the income tax rate. So, it’s a classic strategy and there are legitimate uses of limited liability, absolutely, and there are rules for those companies. 

By and large, businesses are complying. Last years’ figure is something like €540 million – that was our yield from compliance activity. That figure has stayed fairly constant for the last number of years. It’s about half a billion. It might be €600 million; it might be €490 million, but by and large it’s consistent and that’s really positive. It’s positive that we have the recovery but it’s more positive that in a context that we collected €84 billion last year, our compliance activity is staying constant even though the gross amount is going up. I think that’s really important. 

IK: I went through a number of your annual reports for the last ten to 15 years. It appears an awful lot of the wild west stuff from the past has been rooted out. Is that a fair assessment?

NC: I mentioned earlier our previous restructuring. That essentially came out of the offshore bogus non-resident accounts and the PAC at the time, and Jim Mitchell. It was an environment in which it was a mark of honour for certain businesses to not pay their tax. And they wouldn’t have been slow to be boasting about it. You won’t have that happening now. I’m not saying that some people will not pay their tax but the last thing they’ll want to do is talk about it. The data that we have, third party information and our ability to slice and dice it, analyse it on our risk analysis systems, even the wealth stuff that we can put out there – when you turn that into looking at outliers and anomalies, and we would increasingly be doing that, that comes back to data and data quality. 

IK: You also have access to a wealth of third-party sources in recent years both nationally and internationally.

NC: Yeah, and the ability for us to link all that data and then cross-check and prepopulate. We’ve a long-standing relationship with social protection. We publish, annually, a report on farm incomes. That’s based on the links and farm payments and we prepopulate the person’s return, with this third-party data which encourages correct returns. 

IK: Just in terms of your settlement strategy, I know looking there that you settled 127 cases. When do you make a decision on when to settle or when to fight, or how does that work?

NC: The 127 relate to the published settlements. The €540 million that we collect, whether it’s audit or whether the other interventions, it’s all based on a published code of practice that sets out the rules in relation to settlement. And settlements generally will cover tax, interest and penalties and it covers all sorts of arrangements where some of them are very clear-cut. It’s an interpretation of the legislation and they’re often the cases that end up in determinations by the Tax Appeals Commission because there is a doubt about the legislation. 

Our settlement policy is driven from the legislation and set out in our code. I have said this at various public accounts committee meetings that I sometimes wonder why businesses ever get published or ever get prosecuted because they have the opportunity to make disclosures and we would much prefer if businesses conducted a series of self-reviews and made corrections and self-corrections.

IK: Is there any areas of concern for you at the moment or that the Revenue is going to be putting significant resources into?

NC: We’ve chatted about the annual report. The annual report is so much like a history book at this stage and the environment we’re in right now is just so different than anything that any of us could have anticipated. So, I think we just have to be agile and responsive and supportive to businesses. I think we’ll probably be, we may be called upon to do other things in the next while. But I suppose the thing, if we hadn’t had the Covid pandemic, that we would be doing right now is we would be engaged in fairly significant interaction with businesses around PAYE reporting. Because last year was the first year and this year our intention was to engage, I won’t say in a blanket fashion, but engage with people around using the correct RPN, the notification that the employer gets for every payment to employees, the data quality and some of the challenges that we’ve seen in the Wage Subsidy is the amount of strange practices in operating payroll. 

Niall Cody on the shadow economy

I think the shadow economy is shrinking because of the nature of how business is done. One of the things that will be really interesting over the next couple of years is how we have paid for things during the last few months. I am not great for tap and go, or I wasn’t until March. I haven’t used cash for the last three months and I think that the type of systems and all the digital platforms present challenges for tax administrations. But they also present a lot more opportunities and I think that the traditional cash business or the nixer is increasingly shrinking and I think it’s shrinking for all sorts of regulatory reasons as well. 

Like electricians, there’s a lot more regulation around that. I’m just mentioning electricians because I’ve a friend of mine who’s an electrician and we have this discussion every so often, and so I think that the environment changes. 

*****

The border and Brexit

Speaking this week, German Chancellor Angela Merkle said the European Union must prepare for the possibility that talks for a deal with the UK over their future relationship could fail. It was a prescient reminder of the issue that, in the absence of the global pandemic, would be dominating the political and business agenda. 

London and Brussels now have until the end of December to strike a brand new agreement or end their half-century relationship without specific plans for how they intend to trade or coexist in other fields.

Without a new agreement, they would see ties reduced to minimum standards set by the World Trade Organisation with high tariffs and serious disruptions to business. To prepare for the new relationship, Revenue has been actively engaging with business and has hired hundreds of additional staff.

IK: Normally, Brexit would have come up way before now in this interview. But it hasn’t gone away and it appears, judging from the political commentary, it’s looking like a no-deal Brexit. For you, that poses significant logistical challenges that you need to prepare for. 

NC: You’re right. Over the last couple of years, a lot of our time and effort went into preparing for the various different variants of no-deal and the various deadlines. Very early on, we invested on upgrading our IT systems to deal with a 20-fold increase in transactions. So, all that work is done. We engaged in significant recruitment through 2018 and 2019 in the best part of 600 people, nearly, between recruitment and assignment to customs division. Again, we set up customs division as a link to border control to prepare for the process.

We took in a lot of new staff and I’ve been asked at Oireachtas Committees what are they doing since there hasn’t been no-deal yet. Interestingly enough, there’s a cohort of them over the last few months who’ve been involved in contact tracing for the HSE and various other projects. So, we have invested in IT. We’re investing in people. We’ll have to continue, we’ll have to recruit again because obviously in the period there has been some churn and people have gone off and got promoted. On the infrastructure in the ports and airports, we’ve been heavily involved in the plans with our colleagues in Agriculture, Food and Marine, the environmental health wing of the HSE and working with the OPW and the infrastructure group with DPER. 

So, all that work is ongoing. We have engaged extensively with business. There are about 65,000 businesses that are registered with an EORI –  we spent all last year talking about EORI numbers. There are about 3,000 traders who’ve engaged with imports from the UK or exports to the UK, in excess of 50,000 in 2019 who haven’t an EORI number yet. So, they’re a concern for us but some of them will have brought in one large machine or are not regular importers. About 93 per cent of imports are covered by businesses with EORI but we will be engaging again with businesses in July/August around this, we’ll update our figures looking at the last batch and encourage people. We’re operating currently at ports and airports, our staff in a safe environment as much as possible and that’ll have to continue. But it will be massively challenging for us all.

“In some ways, it’s easier for the member states as opposed to the UK, because they’re just another third country.”

Niall Cody

IK: Well if you’ve to get your head around, you know, tariffs and WTO…

NC: The UK will become a third country; they are a third country but they’re in transition right now. So, the tariff system and the EU customs code is actually being built into the IT systems. In some ways, it’s easier for the member states as opposed to the UK, because they’re just another third country. The challenge is the scale of it and the level of checks that have to be done, physical checks. The health and food safety side of it is the real challenge. The computer system will calculate the tariff and the challenge then for the business will be to fund it – and all that goes with that. 

IK: I’m just even thinking of the conversation we’ve had where we’ve gone from WTO tariffs in Brexit to corporation tax to Covid. It’s a wide remit of issues that you deal with on a daily basis. But it must give you tremendous oversight of the economy and how it’s functioning and how people are interacting. 

NC: Ourselves and Social Protection are the two government bodies that have the biggest interaction with the widest range of people. Sometimes our customer base overlaps. But we have the biggest interaction with businesses and citizens across the whole country and in a way, the data that we have gives us great insight. And I think the other agency that uses our information really well is the Central Statistics Office. I’m a big fan of the CSO and the way they increasingly use geographic indicators, building on the Eircode. Some of the presentation stuff is phenomenal. And obviously they have access to all our data and use it very well. 

We don’t always have access to everything they have because obviously – confidentiality. They’re as bad as ourselves in confidentiality. But it does give us great insight. What we’ve tried to do, Keith Walsh and his team have over the last few years tried, is to put as much information as we can, having regard to taxpayer confidentiality, into the public domain to facilitate people like yourself and various commentators, because there’s no lack of people commenting on issues based on partial information. As much as possible, if we can put it out there, that can only help informed debate. 

But our main remit is to fairly and efficiently collect taxes and duties and implement customs controls. We’re not a research agency. Our real job is essentially administering the tax and duty system and to ensure that the State, the exchequer has the funding to allow a properly functioning State.