Ireland

Ireland: If your claim is reviewed

What to expect if Revenue opens a compliance intervention into an R&D credit claim: the 28 day notice letter, a Risk Review or a Revenue Audit, the science test and the accounting test, independent experts, how an intervention ends, and the appeal to the Tax Appeals Commission. What to expect from your adviser, and why to take advice first.

Last reviewed: 13 October 2026

This page summarises the position in Ireland as at 13 October 2026. It is not legal advice and may not reflect later changes. Check the official sources listed below.

Take advice first

A Revenue compliance intervention has deadlines, and the 28 days between the notice letter and the start of the intervention are the window in which a prompted qualifying disclosure can be made. Before you reply to anything, read your engagement letter to see what help it provides, tell your adviser the same day, and take advice from someone who can see the letter and the claim. This page describes the process in general terms from Revenue's own guidance; it is not a guide to handling an intervention, and nothing here replaces advice on your own case.

How Revenue tells you

Revenue checks claims through compliance interventions. A Level 2 intervention is a Risk Review or a Revenue Audit. A Risk Review is a focused intervention on a risk or a small number of risks on a return. A Revenue Audit is an examination of compliance with particular regard to the accuracy of specific returns, statements, claims or declarations. You receive 28 days notice of a Level 2 intervention, and a copy goes to the agent on record. The letter says which type of intervention it is and what it covers, and the intervention is treated as starting 28 days after the date of the letter. A Level 3 intervention, a Revenue Investigation, is for suspected fraud and evasion.1

What Revenue asks for

No supporting documents go in with an R&D claim, but Revenue can ask for them later to verify that the claim is valid. In a compliance intervention on an R&D claim the two main elements are the science test and the accounting test. Revenue may engage qualified independent experts in the relevant field of science or technology. It tells the company who it proposes to engage before disclosing information. The company can object where it has reason to believe there is a genuine conflict of interest, and it has a right of appeal to the Tax Appeals Commission against the use of a particular expert.2

How it ends

In audit cases a final meeting is held with the taxpayer to set out the findings; otherwise Revenue writes to set out the position, and where the returns are correct a letter confirms that the intervention is closed.1 If the credit is reduced, the clawback, interest and penalty rules on the your responsibility page apply.

If you disagree

You can appeal to the independent Tax Appeals Commission against Revenue's findings on a revised assessment, generally within 30 days of the date on the notice of assessment or decision letter. The appeal goes on a Notice of Appeal with a copy of the assessment or decision. Any liability not under appeal must be paid. Revenue's own review procedures apply only to complaints about its handling of the case.1 3 Each of these has a deadline, and the choice is a matter for advice.

What to expect from your adviser

What your adviser must do depends on the engagement letter, which is why the review and audit support clause matters before you sign. In an intervention, the useful things an adviser does are these.

Produce the technical case and the cost workings quickly and in order.
Help the company present the science test and the accounting test, with the people who did the work.
Raise any objection to a proposed expert in time.
Correct any error in the claim through a qualifying disclosure before the intervention starts, if that is the right course on advice.
Tell you plainly what the findings mean and what your options are.

Revenue does not approve agents, and nothing an agent does moves the clawback, interest or penalty off the company.4 If the adviser's help is charged by the hour, agree an estimate and a ceiling before the work starts. The companies under review page and the claim reduced on review page cover the fee side.

Sources

Revenue, Code of Practice for Revenue Compliance Interventions (effective 1 May 2022), sections 1.3.3, 1.3.4, 1.4, 4.1 and 4.11. Back
Revenue, Tax and Duty Manual Part 29-02-03, Research and Development (R&D) Corporation Tax Credit (April 2026), sections 8.6, 8.7 and 10. Back
Revenue, How to make an appeal (24 October 2022). Back
Revenue, Tax and Duty Manual Part 37-00-04b (September 2026); Tax and Duty Manual Part 29-02-06, clawback of relief (November 2022). Back

Official sources

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