Mr. Niall Cody:

When I come before the committee, members ask me to be quick in my responses but we are dealing with complex issues. It would be useful to go back a little on the history. We were one of the first administrations to have a HWI large cases division, LCD. We were leaders in that regard. We reviewed it in 2007 and in 2015. We are now in the process of reviewing and realigning our structure. I want to emphasise the fact that just because a person is dealt with in the HWI unit, or not, does not mean that the same rules and legal basis do not apply. I spoke about the anti-avoidance process. The anti-avoidance teams in the HWI LCD take in the cases that engage in the avoidance process that we have identified, to tackle that process. We have some 1,240 cases of taxpayers who are involved in avoidance schemes that we are challenging. The vast majority of those people are not HWIs at all, but they are being dealt with for the transaction by the anti-avoidance teams in the LCD.

I referred earlier to the Revenue's realignment process that is currently under way. We are trying to do a serious realignment of resources with risk. We have now divided LCD into LCD corporates and LCD HWI. We have also set up a medium enterprise division that deals with the cases under the HWI threshold. This division deals with 15,000 individuals and their tax affairs. I have asked the two assistant secretaries who lead the HWI unit and the medium enterprise divisions that once we have settled down a bit of our resources in this quarter that by the end of the first quarter of next year they would bring forward a proposal to the board on the threshold for the HWIs. I am absolutely confident that we will be reducing that threshold. I want to put more resources into that area. Identifying the resources and freeing up the resources from what they are currently doing is a process. We are going through our structural realignment, motivated by ourselves, which involves a significant change in the structure of the organisation. This will take time to bed in. We are revisiting the threshold. We want to see what will be the implications of, for example, a €20 million threshold and how many cases this would involve. All of those cases are being dealt with by the medium enterprise division. It is a question of how we balance those two.