Section 811A (2A) TCA 1997, as amended by Finance Act 2014, provides an opportunity to persons who had engaged in unacceptable tax avoidance (i.e. entered into a transaction to avoid tax on or before 23 October 2014) to come forward to Revenue on or before 30 June 2015, and settle their affairs in such a way that no surcharge will apply and any interest payable will be capped at 80% of the interest otherwise so payable.
This settlement opportunity is available to persons who had entered into a transaction and either the Revenue had formed the opinion that the transaction was a tax avoidance transaction or the Revenue could have successfully challenged the transaction by forming an opinion under Section 811 TCA 1997 that it was a tax avoidance transaction.
To avail of this opportunity, the taxpayer must make a qualifying avoidance disclosure in writing, containing full details of the transaction and must be signed. It must also be accompanied by full payment of the tax and any interest due.