Irish Revenue issued eBrief No. 097/26 on 21 May 2026, updating Tax and Duty Manual 41A-05-04 on full self-assessment. The amendments clarify exceptions to the four-year rule for assessments, including cases of incomplete disclosure and MAP-related adjustments under section 98 Finance Act 2025, and remove obsolete statutory references.

RF Report

Irish Revenue issued eBrief No. 097/26 on 21 May 2026, relating to updates to Tax and Duty Manual 41A-05-04 on Full self-assessment. The manual sets out the authority of Revenue officers to conduct enquiries, the time limits within which such enquiries may be made, and the statutory time limits applicable for Revenue to make or amend assessments.

Tax and Duty Manual 41A-05-04 – Full self-assessment. Time limits for making enquiries and making or amending assessments – has been amended:

in Paragraph 4.2 to outline the exception to the four year rule for making and amending assessments in cases where a taxpayer has not made a full and true disclosure of all material facts necessary for the making of an assessment for a period;

in Paragraph 4.2 to reflect the amendment in section 98 Finance Act 2025 providing that a Revenue officer may make or amend an assessment outside the normal four year period to give effect to a MAP (Mutual Agreement Procedure) reached under a limited scope treaty; and

in Paragraph 5, to remove an obsolete reference to section 959Z (5) to (8) inclusive, which were deleted by Finance (Tax Appeals) Act 2015.