I propose to take Questions Nos. 424, 425 and 426 together.
I am advised that Revenue is currently collating and reviewing submissions received from employers under the Karshan settlement opportunity up to Friday, 30 January 2026, to assess compliance with the terms set out in the relevant Tax and Duty Manual.
This work is ongoing and, in due course, Revenue will publish aggregated statistics, in compliance with section 851A of the Taxes Consolidation Act 1997.
The Supreme Court judgment in Karshan, delivered in late 2023, provided important clarity on the classification of workers for tax purposes by setting out a structured framework for determining employment status. Revenue designed the Karshan settlement opportunity to support compliance with that clarified framework from 2024 onwards, rather than to retrospectively revisit classifications made in good faith. Therefore, I am advised that there was no requirement- to develop an estimate, internal model or fiscal impact analysis in respect of the Exchequer cost of applying the Karshan judgment for the years 2024–2025, rather than retrospectively.
The Karshan settlement opportunity does not confer a selective fiscal advantage as it was made available to all employers in the State subject to appropriate limitations. The opportunity did not extend to situations where the individual should already have been treated as an employee under the Code of Practice on Determining Employment Status in force prior to October 2023, or where employee status had already been established through a published decision or determination of the Department of Social Protection, the Workplace Relations Commission, the Tax Appeals Commission, or a court.
Section 849 of the Taxes Consolidation Act 1997 provides the Revenue Commissioners extensive Care and Management provisions in relation to the administration of the tax system. Disclosure opportunities have been a feature of the Irish tax system and also a common feature of other self-assessment tax regimes in other Member States and in other countries. They are generally designed as widely available. Disclosure opportunities are seen as best practice at EU and OECD level by securing short and long term tax compliance in a cost effective way. Revenue advises me that the Karshan Disclosure opportunity is compatible with Irish and EU law and is fully within its legal authority. Revenue does not disclose matters relating to legal advice.
