Ms Josephine Feehily:

In order to send in sheriffs and make attachment orders, we must have a crystallised debt. That comes at the end of the process. If there is not crystallised debt, the pursuit in terms of sheriffs and attachments does not arise. The first thing we must do is establish the debt. In recent years, the norm period for us to look back is four years. It is the same length of time as the normal period for which taxpayers can make claims for repayments and so on. To go back further than that we must be able to show fraud and neglect and that is a high bar, but we do get over that bar and in the cases settled in many of our special investigations and in particular in the case of Ansbacher accounts, there are cases that were settled with the estates. A significant number of people are dead and their estates have paid taxes and interest.