Large Cases Division - Revenue Commissioners

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Chapter 14

Large Cases Division

What is a large case?

Companies with turnover greater than €162m or tax payments greater than €16m per annum and individuals with net assets greater than €50m (family members with lower incomes may also be included) or non-residents with substantial economic interests in Ireland. High Wealth Individuals and Professionals district are also responsible for the tax affairs of c600 partners of the nine largest accounting and solicitor firms.

High-level description of Role:

The role of the Large Cases Division is to;

 Carry out customer service and compliance functions in respect of the tax and duty affairs of the State’s largest corporate businesses, high wealth individuals (including the partners in the 9 largest law and accountancy firms), and particular business sectors, including the financial, pensions and motor sectors, regardless of geographic location.

 Ensure its customers understand their tax and duty obligations and entitlements.

 Challenge anti-avoidance schemes.

Structure:

LCD is Sectoral based, the idea being that case managers, mainly at AP and

HEO/AO levels, develop knowledge of how a sector works and build technical capability.

11 Sectoral based Districts:

Alcohol, Tobacco & Multiples

Betting, Food & Media

Financial Services Banking

Financial Services Insurance & Investment Funds

Financial Services Pensions

Information, Communication & Technology

Healthcare & General Manufacturing

Construction, Property, Mining & Energy

Motors, Oils & Transport

Anti-Avoidance, High Wealth Individuals & Professionals 1

Anti-Avoidance, High Wealth Individuals & Professionals 2

Central Audit teams:

LCD has 5 central Audit teams which are used as a divisional-wide resource.

PREM Audit

Customs Audit

E-Audit

VAT Audit

Multi-Tax Audit

Support Branches:

Customer Service

Divisional Office

LCD National Roles:

LCD has a number of national roles within the Revenue Commissioners;

Anti-Avoidance:

The National Anti-Avoidance Branch (NAAB) provides technical assistance on tax avoidance matters in terms of identifying, investigating and litigating tax avoidance.

NAAB also takes the lead role operationally in managing cases challenged under

S.811 TCA 1997 (the general anti-avoidance rule); Protective Notifications; and the

Mandatory Disclosure regime.

E-Audit:

The E-Audit unit develops capacity in the use of E Audit techniques across Revenue.

The Branch also develops and supports the implementation of new strategies to enhance the use of E-Audit.

Customs Valuation:

The Customs Unit holds the national function as respects functional support for complex Customs Valuations.

CREST:

The Crest Unit which is a unit within the Financial Services Banking District manages the Crest system, which administers the collection and repayment of Stamp Duty charged on the electronic transfer of securities.

Transfer Pricing:

Sectoral Districts, in conjunction with CBID, deal with transfer pricing issues, such as correlative relief claims and disputes including Mutual Agreement Procedures and

Advance Pricing Agreements for both LCD and Regional cases.

Classes of Records:

The records held in the Division are those relating to:

 The performance of Revenue operational activities for the taxes and duties of its case-base: the largest businesses and wealthiest individuals;

 The provision of specialist support to other Divisions in the form of antiavoidance consultancy and the development of capability in computer systems audit and forensic accounting; and

 The personnel and logistical supports for these activities.

Delivery of services:

Customer Service:

The aim of the customer service operation is to make it easier for customers to comply with their obligations to Revenue and to reduce their compliance costs. It includes processing returns, correspondence and other contacts quickly and correctly and providing information and assistance, where required.

Compliance:

Compliance involves pursuing those who do not file returns and/or do not pay the taxes/duties for which they are liable.

Audit:

Audit is concerned primarily with verifying the accuracy or otherwise of tax returns filed with a view to recovering any taxes/duties omitted and imposing penalties when appropriate.

Contact Details for Large Cases Division

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