Written Answers Nos. 388-398
393. Deputy Paul Nicholas Gogarty asked the Tánaiste and Minister for Finance if he will clarify his Department's policy on responding to voluntary disclosure requests; and if he will make a statement on the matter. [6452/26]
View answerI understand that this question relates to the Karshan disclosure opportunity that is being run by Revenue and that is available to all employers in the State, across all sectors, provided that they meet the terms as outlined.
This disclosure opportunity arises from the Supreme Court judgement in the case, Revenue Commissioners v. Karshan (Midlands) Ltd. t/a/Domino’s Pizza, which was issued in October 2023. This judgement sets out the factors to be considered when classifying an individual’s employment status for tax purposes, and whether workers are to be classified as being under a contract of service (employee), or a contract for service (self-employed) as regards to their income tax treatment.
While there has been no recent change to tax policy or tax treatment in this area, as a decision of the Supreme Court, the judgement is binding and must be applied to all sectors and all businesses operating in Ireland. Revenue, in carrying out its statutory function, is obliged to apply the judgement when undertaking its compliance activities.
In May 2024, Revenue published comprehensive guidance to outline its position in relation to the application of the Karshan judgement. This guidance explains the five step framework that is now required to be applied and provides a number of practical examples to assist businesses and organisations. Within this guidance, Revenue encouraged businesses to “urgently and comprehensively review arrangements with all workers and determine their employment status for taxation purposes”.
In September 2025, following consultation with certain stakeholders and tax practitioners, and in recognition of the implications of the judgement, Revenue provided an opportunity to employers to self-correct payroll tax issues arising from bona-fide classification errors for 2024 and, where necessary, 2025, without the application of interest or penalties. Revenue provided a window of over four months for this, with 30 January 2026 being the closing date for receipt of disclosures. I note that, in relation to this matter, the Revenue Commissioners issued a press release on 15 January 2026. This press release confirms that businesses that are preparing disclosures and that, after the submission deadline, identify a need to amend the details of a disclosure which has already been submitted, can do so and that Revenue will accept those amendments in accordance with the Code of Practice for Revenue Compliance Interventions where certain other conditions are met. This press release can be found on Revenue's website here - www.revenue.ie/en/corporate/press-office/press-releases/2026/pr-011526-reminder-of-disclosure.aspx
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.
The independence of the Revenue Commissioners in their dealings with the tax affairs of any individuals, business or other entity under tax and customs legislation is critical to maintaining the integrity of the taxation system. Legal effect in this matter is provided under Section 101 of the Ministers and Secretaries (Amendment) Act, 2011. In line with this, the operation of the disclosure opportunity is a matter for the Revenue Commissioners.
397. Deputy Mairéad Farrell asked the Tánaiste and Minister for Finance the number of employers that have registered an intention to participate, filed a disclosure, and completed settlement under the Karshan Disclosure Opportunity as of 31 January 2026; the total value of tax, USC and PRSI regularised; the number of affected workers for whom manual PRSI records have been created; and if he will make a statement on the matter. [6568/26]
View answer398. Deputy Mairéad Farrell asked the Tánaiste and Minister for Finance if he will provide a breakdown of Karshan Disclosure Opportunity participants by NACE sector, indicating the number of disclosures received from State-linked entities (details supplied); and if he will make a statement on the matter. [6569/26]
View answer402. Deputy Mairéad Farrell asked the Tánaiste and Minister for Finance for the estimated fiscal cost to the Exchequer of limiting Karshan-related liabilities to the years 2024–2025 rather than the full retrospective period of 2010–2023; and if he will make a statement on the matter. [6573/26]
View answer403. Deputy Mairéad Farrell asked the Tánaiste and Minister for Finance the number of employers denied access to the Karshan Disclosure Opportunity on the grounds of deliberate or careless misclassification; the number of investigations opened since September 2025 under the Code of Practice for Revenue Compliance Interventions; and if he will make a statement on the matter. [6574/26]
View answerI 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.
