Ireland: Revenue code of practice | Research Credit Integrity Alliance

Revenue's Code of Practice for Revenue Compliance Interventions sets out how Revenue conducts compliance work and how taxpayers can correct errors. It is not specific to the research and development (R&D) corporation tax credit, but Revenue's R&D manual applies it to R&D claims. This page sets out the parts of the Code most relevant to correcting an R&D claim.

Status and scope of the Code

The current Code took effect on 1 May 2022 and applies to interventions notified after that date. It replaced the Code of Practice for Revenue Audit and other Compliance Interventions 2019.1 It applies to all taxes and duties except Customs.1 The Code states that taxpayers' rights and obligations are set by law and are not restricted or altered by the Code, and that it must not be used to avoid or delay the payment of tax, interest or penalties correctly due.1

The Code does not contain a section specific to the R&D credit.1 Revenue's R&D manual states that, where an R&D intervention results in a settlement, penalties will apply in line with the legislation and the Code, and that publication may also apply.2

Correcting a claim before Revenue intervenes

The Code describes several ways for a taxpayer to regularize its position.1

Self-correction without penalty

A taxpayer may self-correct without penalty if it notifies Revenue in writing or through the Revenue Online Service (ROS) of the adjustment, provides a computation of the correct tax and statutory interest, and pays in full.1 The Code notes that submitting an amended return on ROS is not, by itself, notification: written notification is required.1

For corporation tax, the time limit for self-correction is 12 months from the filing due date of the return.1 Self-correction is not available once Revenue has notified a compliance intervention, and does not apply to deliberate defaults. Self-correction does not, by itself, trigger an intervention, but Revenue may begin one if it identifies a risk.1

Innocent errors and technical adjustments

No penalty applies to an innocent error, meaning one that is not deliberate and not due to a failure to take reasonable care, or to a technical adjustment arising from a difference in the interpretation or application of the law. Section 1077F(10) of the Taxes Consolidation Act 1997 (TCA 1997) gives these practices a legislative basis.13

Qualifying disclosures

A qualifying disclosure is a written disclosure of complete information about all matters giving rise to a liability that attracts a penalty, with a declaration that it is correct and complete and payment of the tax and interest.3 It reduces the penalty and, under the Code, a taxpayer whose qualifying disclosure is accepted is not published in the list of tax defaulters.13

Type of disclosure	When it can be made
Unprompted	Before Revenue notifies a Level 2 or Level 3 intervention13
Prompted	After notification of a Level 2 intervention but before it starts; written notice of intention must be given within 21 days of the issue of the notification, and a maximum of 60 calendar days, running from the day the notice of intention is given, may then be requested to make the disclosure1

When Revenue intervenes

The Code sets out three levels of intervention, from requests to self-review up to investigation.1 For an R&D claim, Revenue's manual states that the two main elements reviewed are the science test and the accounting test.2 The reviews and audits page describes the levels.

Full cooperation

Reduced penalties depend on full cooperation with the intervention as well as on disclosure.13 The penalties page sets out the percentages under section 1077F.

Categories of default

The Code applies the categories in section 1077F: deliberate behavior, careless behavior with significant consequences, and careless behavior without significant consequences.1 "Careless" means failure to take reasonable care. The Code's test of reasonable care asks whether a taxpayer of ordinary skill and knowledge, properly advised, would have foreseen as a reasonable probability that an act or omission would cause a tax underpayment.1 A default has significant consequences where the tax underpaid exceeds 15 percent of the tax correctly payable.13

For R&D claims, Revenue's manual states that a penalty under section 1077F(3) and (4) is chargeable on amounts offset, paid and unpaid.2

Tax practitioners under the Code

The Code recognizes the role of tax practitioners in helping taxpayers and sets out Revenue's expectations of them:1

Revenue expects all tax practitioners preparing returns and representing taxpayers to act honestly and comply with relevant laws and regulations.
In exceptional cases where a practitioner actively engages with a client to assist in tax evasion or avoidance, Revenue will seek a penalty under section 1055 or press for prosecution under section 1078(2).
Revenue expects a practitioner acting for a taxpayer to provide information that, to the best of the practitioner's knowledge, is a true representation of the taxpayer's affairs.
Under section 851A, Revenue may refer an agent to a professional body in the most serious cases where the agent's work does not meet that body's standards.

The Code also states that the taxpayer cannot devolve the responsibility of making a correct return to an agent.1 Notifications of Level 2 and Level 3 interventions go to the taxpayer and also to the agent where relevant.1

Reviews and appeals

The Code provides for complaints about Revenue's handling of a case through Revenue's review procedures, and for appeals about liability to the independent Tax Appeals Commission.1 See disputes and appeals.

Summary

Stage	What the Code provides
Before any contact	Self-correction without penalty within 12 months of the CT return due date1
After a Level 2 notification	Prompted qualifying disclosure before the intervention starts1
During the intervention	Reduced penalties for full cooperation13
At settlement	Penalties under section 1077F; publication unless an exclusion applies12

Sources

Revenue Commissioners, Code of Practice for Revenue Compliance Interventions (effective 1 May 2022), sections 1, 1.1, 1.3.2, 1.5.3, 1.5.4, 2.2, 2.2.1, 2.2.2, 2.3, 2.4, 2.8 to 2.10.1, 2.17, 4.6, 4.11 and 5.2. https://www.revenue.ie/en/tax-professionals/documents/code-of-practice-revenue-compliance-interventions.pdf (accessed 11 October 2026). Back
Revenue Commissioners, Tax and Duty Manual Part 29-02-03, Research and Development (R&D) Corporation Tax Credit (last updated April 2026), sections 8.7 and footnote 60. https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-29/29-02-03.pdf (accessed 11 October 2026). Back
Revenue Commissioners, Notes for Guidance, Taxes Consolidation Act 1997, Finance Act 2025 edition, Part 47, section 1077F, subsections (1), (6) to (8) and (10). https://www.revenue.ie/en/tax-professionals/documents/notes-for-guidance/tca/part47.pdf (accessed 11 October 2026). Back