Dáil Éireann Debate, Thursday - 21 May 2026
210. Deputy Pearse Doherty asked the Tánaiste and Minister for Finance to provide an assessment of the Karshan Settlement Opportunity given the fact that 286 employers received tax adjustments for over 6,600 employees making specific reference to the construction sector; the next sets to ensure compliance from companies that have not engaged in the settlement opportunity; and if he will make a statement on the matter. [38488/26]
View answerThe Supreme Court judgment, delivered in October 2023 in the case of Revenue v Karshan (Midlands) Ltd. trading as Domino’s Pizza, provided important clarity on the classification of workers for tax purposes by establishing a structured five test framework for determining employment status. Prior to the judgment, employers assessed worker classification based on the information and guidance available at the time.
In that context, Revenue announced the Karshan Settlement Opportunity in September 2025, as set out in the Tax and Duty Manual - Revenue Guidelines – Settlement arrangement arising from Revenue v Karshan (Midlands) Ltd. trading as Domino’s Pizza. The settlement opportunity provided businesses with a mechanism to regularise payroll tax issues for 2024 and 2025 arising from bona fide worker classification errors, without the application of interest or penalties.
To avail of the settlement opportunity, businesses were required to submit a disclosure by 30 January 2026 and either pay all related liabilities in full or request a Phased Payment Arrangement at the time of submission.
Disclosures were received from a broad range of sectors and varied significantly in scale, from employers regularising a single employee to employers regularising more than 100 employees. Many of the employments concerned were part-time or seasonal in nature.
On 7 May 2026, Revenue published preliminary statistics on the Karshan Settlement Opportunity. These figures show that 286 employers made disclosures involving over 6,600 employees, with total tax adjustments of approximately €26.7 million. Within the construction sector specifically, 46 employers made disclosures involving over 150 employees and total tax adjustments of approximately €5.2 million.
Revenue is currently undertaking verification work in respect of the 286 submissions received to ensure compliance with the terms of the settlement opportunity as published in September 2025.
More broadly, Revenue continues to monitor employers across all sectors, including the construction sector, through ongoing compliance programmes which identify cases for intervention based on a range of risk indicators, including the potential misclassification of workers.
As outlined in the Tax and Duty Manual Revenue Guidelines – Settlement arrangement arising from Revenue v Karshan (Midlands) Ltd. trading as Domino’s Pizza, where employers did not avail of the Karshan Settlement Opportunity and liabilities subsequently arise, Revenue will, in addition to pursuing collection of any underpaid taxes, treat the default as a failure to correctly operate PAYE, USC and PRSI obligations. In such cases, Revenue will apply the relevant statutory provisions and seek to impose interest and penalties as appropriate.
