Taxes Consolidation Act 1997 section 891L

Administrative cooperation

Section 891L sets out how joint audits may be conducted under the EU Directive on Administrative Co-operation 2021/514 (DAC7).

  • A competent authority of another EU Member State may request Revenue to conduct a joint audit on a person of common or complementary interest, and Revenue must respond within 60 days.
  • Revenue may authorise foreign tax officials as "nominated officers" who can accompany Irish authorised officers, interview individuals and examine records during the audit.
  • The joint audit must be conducted in a pre-agreed and coordinated manner in accordance with Irish law, and nominated officers are subject to restrictions including legal professional privilege and private residence protections.
  • A final report must be prepared at the conclusion of the audit, and the person audited retains the same rights and obligations as in a domestic Revenue compliance intervention.

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