New Enhanced Compliance Engagement Framework

High Wealth Individuals (HWIs), Risk Reviews, Audits and Investigations

Revenue Compliance Interventions, Qualifying Disclosures, Tax Return filings, Irish Tax Compliance, High Wealth Individuals (HWIs)

 

 

New Revenue Guidance on Tax Compliance

The Revenue Commissioners have introduced guidance on the Enhanced Compliance Engagement (ECE) framework for high-wealth individuals (HWIs) within the High Wealth and Financial Services Division (HW&FSD), running as a pilot until 31st December 2027.  It will be reviewed by Revenue in 2028. The framework, designed to foster collaboration and reduce enquiries, comprises a tax pack compliance review of submitted computations and a mechanism for obtaining opinions on significant transactions. Key benefits for HWIs include a dedicated case manager and the retention of rights to make unprompted qualifying disclosures during the Level 1 Revenue compliance intervention process.

 

You can review the full guidance in the new Revenue ebriefs:

 

https://www.revenue.ie/en/tax-professionals/ebrief/2026/no-1112026.aspx

 

 

https://www.revenue.ie/en/tax-professionals/ebrief/2026/no-1122026.aspx

 

 

 

 

 

Overview & Timeline

 

The Revenue Commissioners have launched the Enhanced Compliance Engagement (ECE) framework. It is managed by the High Wealth and Financial Services Division (HW&FSD).

 

 

Who is the Target Audience?

High Wealth Individual (HWI) taxpayers.

 

 

What is the Format?

It’s a voluntary pilot scheme.

 

 

What is the Duration?

Effective from Q2 2026 to 31 December 2027.

 

 

What is the Review Date?

Revenue will review the framework in 2028.

 

 

What level of Commitment is required?

No formal agreement is required to participate.

 

 

 

What level of Flexibility is offered?

Taxpayers can opt-in at any stage or for any single year.

 

 

 

 

 

Key Elements of the Revenue Compliance Framework

 

What is the process?

Taxpayers submit backup tax computations and supporting documentation after filing returns.

 

 

Who are they submitted to?

Documents should go directly to an assigned dedicated case manager.

 

 

What’s the purpose of this?

It helps Revenue understand the return filed, especially regarding exceptional matters which differ from submissions made in previous years.

 

 

How do Revenue classify this?

Handled as a Level 1 Revenue Compliance Intervention under the Compliance Intervention Framework.

 

 

What is the benefit to the Taxpayer?

Taxpayers retain the right to make an unprompted qualifying disclosure or penalty-free self-correction.

 

 

 

 

Benefits to HWI Taxpayers

 

 

It’s a Personalized Service

Assignment of a dedicated case manager to the account.

 

 

Risk Reduction 

Lowered exposure to interest charges and future tax penalties.

 

 

Real-Time Resolution

Deals with compliance matters quickly to lower compliance costs.

 

 

Certainty

Increased assurance regarding return accuracy and transaction tax implications.

 

 

Strategic Planning 

Opportunity for early pre-engagement on major financial transactions.

 

 

 

 


For all your tax advisory and compliance requirements including help preparing and filing your Tax Returns and Qualifying Disclosures, please contact us at info@accountsadvicecentre.ie

 

 

 

 

 

Please be aware that the information contained in this article is of a general nature.  It is not intended to address specific circumstances in relation to any individual or entity. All reasonable efforts have been made by Accounts Advice Centre to provide accurate and up-to-date information, however, there can be no guarantee that such information is accurate on the date it is received or that it will continue to remain so. This information should not be acted upon without full and comprehensive, specialist professional tax advice.