I am advised that Revenue maintains a register of disclosures received under the mandatory disclosure regime and undertakes a detailed review of each submission. While the effectiveness of the regime is kept under ongoing consideration, no formal review has been conducted since the introduction of this regime.
The table below sets out the number of mandatory disclosures that have been made since the regime was enacted until the end of March 2026, all of which were reported by promoters, in respect of 571 taxpayers. Due to its obligation to maintain taxpayer confidentiality, as provided for in Section 851A of the Taxes Consolidation Act (TCA) 1997 data in relation to the cases under examination cannot be provided. Revenue only provide data in relation to groupings of 10 or more taxpayers. The table includes five submissions under the regime which were determined to be not valid disclosures.
|
Year
of Receipt
|
Number of
Participants
|
MD
Numbers
|
|
2011
|
510
|
1-7
|
|
2012
|
<10
|
8
|
|
2014
|
38
|
9 & 10
|
|
2017
|
17
|
11
|
|
2021
|
<10
|
12 & 13
|
|
2022
|
<10
|
14
|
|
2023
|
<10
|
15 – 17
|
|
Total
|
571
|
|
Failure to comply with this regime may result in an advisor or promoter becoming liable to a civil penalty, as provided for in section 817O of the TCA 1997. The quantum of penalty is related to the level of non-compliance with the reporting requirement. I am advised by Revenue that to date they have not identified any such non-disclosure cases.
