Section 164 is an enabling provision that will allow the Revenue Commissioners to oblige certain categories of taxpayer to file returns and pay tax electronically. There are considerable benefits from electronic interaction with the Revenue but I consider it desirable that the move to electronic filing and payment be achieved to the greatest extent possible on a voluntary basis. Save in exceptional circumstances, I do not envisage bringing the new provisions which are subject to a commencement order into effect until further consultation has taken place with practitioners and there is a fuller understanding of the reasons more voluntary use is not being made of electronic filing for certain taxes or categories of taxpayers.