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Key statistics for 2024
Tax receipts
Net tax receipts for the Irish Exchequer rose substantially during 2024. €152.9bn in gross receipts were collected in 2024, including €122bn in gross tax receipts and €30.9bn in non-Exchequer receipts. Net tax receipts were €107.1bn. The past few years have seen a dramatic increase in Ireland’s net exchequer receipts – in 2017, Revenue collected €50.4bn in net exchequer receipts, but in the seven years since 2017 this figure has more than doubled, to €107.1bn.
The largest net tax receipts in 2024 arose from corporation tax (€39.1bn, comprising 36% of the total), income tax (€35.1bn, comprising almost 33% of the total), and VAT (€21.9bn, comprising almost 20% of the total). These are the three largest tax heads in Ireland, accounting for approximately 89% of Revenue’s total net receipts in 2024, and each of these tax heads saw growth in 2024: corporation tax receipts were up €15.3bn, income tax receipts were up €2.2bn and VAT receipts increased by €1.7bn.
Audit levels
Approximately 273,000 audit and compliance interventions were carried out in 2024, a slight decrease from the 290,000 interventions carried out in 2023. The total yield arising from audit and compliance interventions was €591m in 2024, which was down on the figure of €787m yielded in 2023. Tax settlements amounting to €28.1m were agreed in respect of 86 taxpayers.
In 2024, Revenue specifically focused its compliance activity on the following risk areas:
In its report, Revenue welcomed the Court of Appeal’s judgement in the case of Thornton v. Revenue Commissioners which endorsed Revenue’s position that a scheme in which artificial trading losses were generated to be set off against other income sources to reduce tax liability, constituted a tax avoidance scheme.
Revenue also emphasised the wide-reaching implications across all sectors of the Supreme Court’s judgement in Revenue Commissioners v. Karshan (Midlands) Limited, whereby a five-step framework to be used in determining the existence of a contract ‘of service’ or ‘for service’ (employee v contractor) was outlined. Following the judgement, Revenue published a new Tax and Duty Manual in May 2024, titled ‘Revenue Guidelines for Determining Employment Status for Taxation Purposes’, to assist businesses in understanding the implications arising from this judgement.
MAP, APAs and exchanges of information
As in previous years, the number of information requests made by foreign tax authorities is considerably greater than the requests made by Revenue (2,438 requests for mutual assistance received, in contrast with 456 requests issued by Revenue). Most requests received by Revenue come from other EU Member State tax authorities: 1,911 such requests were received in 2024, an increase on the 1,777 such requests received in 2023, while 527 requests were received from other non-EU countries.
Reporting under DAC7 commenced in 2024, and data was shared on all categories of information with all EU Member States. The categories of relevant activities include the rental of immoveable property, personal services, sale of goods and rental of transportation.
Transfer Pricing Mutual Agreement Procedures (MAPs) disputes increased, with 31 such cases initiated in 2024. The number of outstanding transfer pricing MAP cases increased to 98, as of 31 December 2024. Non-transfer pricing MAP cases decreased in 2024. 33 such cases were initiated in 2024, which was a significant decrease on the 53 such cases initiated in 2023. 24 transfer pricing MAP cases and 43 non-transfer pricing MAP cases were completed by Revenue in 2024, which was a material increase on the 16 transfer pricing and 35 non-transfer pricing cases completed by Revenue in 2023.
In 2024, 23 new bilateral Advance Pricing Agreements (APAs) requests were received, 10 APAs were concluded, and 1 APA request was withdrawn. At year end, 80 APA cases were open.
Revenue also noted that the first EU Council meeting to begin DAC9 negotiations took place in November 2024. DAC9 will facilitate the exchange of top-up tax information between EU Member States, as required by the Pillar Two Directive. Additionally, drafting work continued throughout 2024 on the GloBe Information Return Multilateral Competent Authority Agreement, and it was published by the OECD in January 2025.
Revenue opinions
The Revenue Technical Service provided 80 Relevant Tax Opinions on complex technical issues to taxpayers, which was consistent in number with the 80 such technical opinions issued in 2023. These opinions touched on issues including withholding taxes (44), corporation tax (11), reconstructions and amalgamations (7), close company surcharges (7) and stamp duty (6).
The report references a reminder which was issued in December 2023, which concerned the maximum period of five-year validity in respect of opinions issued in 2018. Taxpayers wishing to continue to rely on such opinions from 2018, on or after 1 January 2024 were required to make an application for their renewal or extension on or before 29 March 2024. Six such applications were received.
Customs
The report noted that Revenue processed over 50m customs declarations in 2024 in respect of imported goods, which represents an exponential increase when compared with the 1m customs declarations processed in 2020. This increase is primarily a result of Brexit and the growth in eCommerce. Revenue also noted that in May 2023, the European Commission had put forward proposals for a comprehensive reform of EU customs law, which was the subject of intensive discussion throughout 2024. Revenue played an active role in these discussions, with a view to ensuring that Irish trade practices and characteristics are adequately provided for under the proposals.
Government supports
Revenue’s Debt Warehousing Scheme, which had been introduced in response to businesses experiencing cashflow and trading difficulties at the outset of the Covid-19 pandemic, ended on 1 May 2024. In 2024, €284m of warehoused debt was paid by taxpayers, and by 31 December 2024, €1.07bn of warehoused tax debt was available for collection. Approximately €1bn of this is being collected through PPAs, whilst a further €54m is being actively pursued. Over the entire duration of the Debt Warehouse Scheme, €172m was deemed uncollectable.
Priorities for 2025
Key priorities for Revenue in 2025 include:
For more information on this, please contact Paul Fahy, Partner and Head of Tax, Cian Ryan, Associate, or any member of A&L Goodbody's Tax team.
This article was prepared with assistance from Tom Anders and Akshat Arora, Trainee Solicitors.
Date published: 26 May 2025
