I propose to take Questions Nos. 397, 398, 402 and 403 together.
I am advised by Revenue that Section 851A of the Taxes Consolidation Act 1997 (TCA) prohibits Revenue from sharing any information which can either directly or indirectly identify the taxpayer to whom it relates, for example the specific entities mentioned. In any event, the deadline for the disclosure initiative is Friday 30 January 2026, as such a businesses may still avail of the disclosure initiative.
It may be of interest to the Deputy that the Karshan disclosure initiative is available to all employers in the State and across all sectors, provided that they meet the terms as outlined in the disclosure initiative. Detailed guidance on this disclosure initiative is set out in Tax and Duty Manual ‘Settlement arrangement arising from Revenue v Karshan (Midlands) Ltd. trading as Domino’s Pizza’ which is available at www.revenue.ie/en/tax-professionals/tdm/compliance/audit-and-other-compliance-interventions/karshan-settlement-guidance/karshan-disclosure-opportunity-guidance.pdf.