Mr. Niall Cody:

I thank the Chairman and members for the invitation to attend today's meeting of the Committee of Public Accounts on Revenue's investigation of Irish-resident HSBC Swiss account holders. As we have sent a detailed report to the committee in response to questions raised in early February, I will not go into that level of detail. However, I would like to give an overview of Revenue's offshore investigations, of which the investigation into HSBC's Swiss account holders is part. I should state my obligation to uphold taxpayer confidentiality, as provided for in section 851A of the Taxes Consolidation Act 1997.

By way of context, it is important to be aware that, prior to receiving the information from the French tax administration, Revenue had identified the use of offshore accounts as a serious tax risk to the Exchequer. A dedicated branch, the offshore assets group, was set up in 2001 and its main purpose was to uncover and confront the use of offshore accounts by Irish resident individuals. To date, the offshore assets group has secured in excess of €1 billion for the Exchequer. From 2002 to 2012, we obtained 20 High Court orders against financial institutions in seeking details of transfers to and from offshore accounts in other jurisdictions. In 2009 specific orders were directed at transfers to and from Switzerland. In March 2010, when Revenue became aware that the French tax administration had come into possession of information on accounts held with HSBC Swiss, the then chairman immediately wrote to it, requesting data related to Irish residents. The French administration provided us with this information on 23 June 2010. The data contained information on accounts of individuals and corporates, with more than 98% of the total funds identified as being related to the funds industry. As set out in our report, the maximum value of assets in accounts of Irish individuals was $29 million, which at the time was equivalent to €22 million. A detailed breakdown of the cases involved is set out in the report.

Each individual and corporate listed was examined and 33 Revenue investigations were initiated following analysis of the data. Four cases were selected for investigation with a view to criminal prosecution and three cases were successfully prosecuted with one still under way. Of the 33 investigations, 27 have been completed with the remainder ongoing. Settlements were made in 19 investigations and €4.6 million was recovered, over 60% of which relates to interest and penalties.

In conclusion, I am satisfied that Revenue fully investigated the data received from the French tax administration. I can assure the committee that all of the account details provided were risk assessed by the offshore assets group with a view to investigation to recover any tax due together with interest and penalties. Suitable cases were also prosecuted.

Revenue has a considerable track record in tackling serious tax evasion. Since 1998 we have conducted a series of special investigations which yielded in excess of €2.7 billion in tax, interest and penalties. Our approach to tackling offshore tax evasion has been adopted by the OECD as best practice and has been adopted by other tax authorities. Practical measures are now under way at OECD and EU level to further improve the exchange of information between tax administrations and thereby limit the opportunity to avail of bank secrecy to facilitate tax evasion. I will be glad to provide any clarification on the details set out in the report, subject to taxpayer confidentiality.