Ms Josephine Feehily:

Some of them engaged in a self-review process in respect of non-regular payments, if I may put it that way. We are satisfied that the majority of cases would be categorised as innocent or technical errors if voluntary disclosures were to be made. Innocent error and technical error are categories in our code of practice for disclosures. Everybody knows how to do payroll and our involvement was limited to ensuring they understood the employment classification issues. A code of practice on that topic is publicly available. Sometimes they might wonder whether something is an employment. Cross-border VAT issues arise in other cases which are very complex for public bodies. In the event that they were procuring across borders we advised them to speak with us if they had any doubts. In the case of non-regular or not recurring engagements - I do not mean irregular in an accounting sense - they would have needed advice.