Mr. Niall Cody:

Again, on various occasions when we have come before the committee we have referred to our risk-analysis system. We have quite sophisticated technology at our disposal and we have access to a huge level of third-party data sources. My predecessors also referred to our REAP system when they came before the committee. We continually risk-rate our cases and one of the clear indicators of risk is previous behaviour. Built into our risk-analysis system are the results of previous investigations and audits and details of prior non-compliance. It is one of the factors - it is not the only one - and we would continually monitor the same cases. Obviously, there are individuals who have engaged in tax evasion and whose activities we have not yet uncovered. Constant risk analysis and risk assessment in respect of our entire case database are key to our overall compliance programme. Previous behaviour is one of the factors involved.

We also have a dedicated re-audit programme. When I used to perform audits in the 1980s and 1990s, one of the issues about which we were always concerned was that once we secured an audit yield in respect of a case and once our work was done, the business involved immediately tried to recover that yield. As a result, built into our system is a programme of constant monitoring and re-auditing. Unfortunately, the re-auditing function shows that, on occasion, those who previously engaged in tax evasion and who made settlements reoffend. In the context of our code of practice, the penalties we imposed are stepped up in respect of those who are discovered to have deliberately defaulted on a second occasion. In other words, the consequences are more serious.