We will now resume in public session. This morning we will engage with the Office of the Revenue Commissioners to examine its 2024 appropriation accounts. On behalf of the committee I welcome everyone here this morning. From the Office of the Revenue Commissioners I welcome Mr. Niall Cody, Chairman and Accounting Officer, Ms. Ruth Kennedy, director general of customs; and Ms. Leeann Kennedy, principal officer and Revenue's Oireachtas committee liaison; from the Department of Public Expenditure, Infrastructure, Public Service Reform and Digitalisation I welcome Mr. Dermot Nolan, principal officer, who is attending in a representative capacity; and I welcome officials from the Office of the Comptroller and Auditor General, including Mr. Seamus McCarthy, Comptroller and Auditor General, who is a permanent witness to the committee; and Ms. Niamh Kilkenny, audit manager. They are all very welcome here this morning.

Before we begin I wish to explain some limitations to parliamentary privilege and the practice of the Houses as regards reference witnesses may make to other persons in their evidence. The evidence of witnesses physically present or who give evidence from within the parliamentary precincts is protected, pursuant to both the Constitution and statute, by absolute privilege. This means that they have an absolute defence against any defamation action for anything they say at the meeting. However, they are expected not to abuse this privilege, and it is my duty as Cathaoirleach to ensure this privilege is not abused. Therefore, if their statements are potentially defamatory in relation to an identifiable person or entity, witnesses will be directed to discontinue their remarks. It is imperative that they comply with any such direction.

Witnesses are also reminded of the long-standing parliamentary practice that they should not criticise or make charges against any person or entity by name or in such a way as to make him, her or it identifiable, or otherwise engage in speech that might be regarded as damaging to the good name of the person or entity. Therefore, if their statements are potentially defamatory in relation to an identifiable person or entity, they will be directed to discontinue their remarks. It is imperative that they comply with any such direction.

I now call on the Comptroller and Auditor General, Mr. Seamus McCarthy, to make his opening statement.

The account of the receipt of revenue of the State collected by the Revenue Commissioners is the primary report on the sources of the State's income, including tax payable directly into the Exchequer, and other forms of income such as social insurance contributions, health insurance levy receipts and local property tax receipts.

The 2024 account of the receipt of revenue of the State records net receipts of taxes and duties amounting to €107.1 billion, an increase of €19.9 billion, or 23%, when compared to 2023. Corporation tax receipts comprised the largest receipts stream in 2024, boosted by the receipt of €10.9 billion as part of the winding down of the Apple escrow account following the judgment by the Court of Justice of the European Union that Ireland had in the past granted the Apple Group unlawful state aid in how its tax affairs were dealt with.

In addition to tax receipts paid to the Exchequer, net receipts collected by Revenue on behalf of other agencies and funds increased from €26.2 billion to €30.7 billion, an increase of 17%. Pay-related social insurance contributions and VAT one-stop-shop scheme receipts together account for the majority of non-Exchequer receipts. I issued a clear audit opinion in relation to the Revenue account.

All the expenses incurred by Revenue in the exercise of its functions are charged to Vote 9. Certain receipts in relation to Revenue’s operations, including fee income for agency services it provides, are also accounted for in the appropriation account.

Revenue’s total gross expenditure in 2024 was €581 million, with salary costs of €394 million accounting for almost 68% of the expenditure. Taking account of appropriations-in-aid of €64.7 million, net expenditure amounted to €516 million. At the end of 2024, there was a surplus of €15.8 million for surrender to the Exchequer.

I issued a clear audit opinion in relation to the appropriation account. However, I drew attention to non-compliance with procurement rules and to a payment redirection fraud that occurred in 2024, disclosed by the Accounting Officer in the statement on internal financial control. The payment of €343,000 made by Revenue was recovered in full, and steps have been taken to tighten payment controls.

In addition to auditing the Revenue account and Vote 9, I have a specific remit to examine and report on whether the systems and controls in place are adequate to secure an effective check on the assessment, collection and proper allocation of the revenues of the State, and to ascertain whether the way they are employed and deployed is adequate. Chapter 18 examines Revenue’s approach to the assessment and collection of carbon taxes and assesses more broadly whether the increases in carbon tax receipts since 2020 have been allocated and spent on the targeted schemes and programmes. The stated aim was that the increased receipts would be used to fund expenditure including that related to just transition schemes, retrofitting and sustainable farming. We found that between 2020 and 2023, €1.36 billion in increased carbon tax revenue was allocated by the Department of Public Expenditure to specified expenditure programmes across five departmental Votes. However, because the expenditure was less than the amounts provided and had to be surrendered, or because funding was mixed in with other core funding, only 61% of the sum allocated could be verified as having been spent on additional carbon tax measures.

Chapter 19 examines Revenue’s systems and procedures for assessing and collecting the sugar tax introduced in 2018, along with its approach to identifying and tackling possible non-compliance. Net receipts totalled €172 million between 2018 and 2023, with annual net receipts decreasing from €33 million in 2019 to €29 million in 2023. The extent to which the decline in receipts was due to either product reformulation by manufacturers or changes in consumption patterns is difficult to determine. Between 2018 and 2023, Revenue carried out 126 compliance interventions for the sugar tax, yielding a total of €426,000. The report made two recommendations around the approval process for sugar tax repayment claims, and both were accepted by Revenue.

Chapter 20 reviews Revenue’s approach to monitoring and managing taxpayer compliance, focusing on the measures Revenue has in place to assess, detect and deter non-compliance. Unlike in some other jurisdictions, there is no official estimate of the level of tax evasion in Ireland. We noted that the numbers of risk-based audits, investigations and non-audit interventions carried out annually by Revenue have been steadily declining since 2016. However, the additional tax yield from that activity has remained relatively stable year on year, indicating that detection work is generally well targeted.

Chapter 21 reviews the circumstances around the settlement reached with a retailer that was considerably less than the original assessed liability in respect of the plastic bag levy. In 2009, following an audit of a retailer, Revenue issued notices of assessment for an aggregate outstanding amount of €36.6 million in respect of plastic bag levies due for the period 1 July 2004 to 30 June 2008. The retailer appealed Revenue’s assessment of liability and commenced legal proceedings, which extended over many years. In preparation for the appeal hearing in 2021, Revenue reviewed the calculations supporting its November 2009 notices of assessment and identified a number of issues. On the basis of that review, Revenue reduced the estimated liability to €8.5 million, which was less than one quarter of the original demand. This assessment was confirmed by the Tax Appeals Commission in September 2023. Having consulted the Department of Climate, Energy and the Environment, Revenue subsequently accepted a settlement offer of €5 million from the retailer, which was 59% of the assessed liability.

Chapter 22 reviews the key trends in taxable rental income over a six-year period, from 2017 to 2022, and considers the systems and procedures Revenue has in place to facilitate the assessment and timely collection of tax on rental income. In 2022, gross domestic rental income declared was around €8 billion, comprising €4.8 billion declared by individuals and €3.2 billion declared by companies. Most rental income declared by companies relates to commercial properties, while individuals primarily declared rental income from residential properties. Companies appear to be able to use deductible expenses, capital allowances and losses to reduce their overall taxable rental income more effectively than individual owners of rental property.

Revenue’s primary focus is on taxpayers and their compliance with applicable tax law rather than on the impact of taxation on economic sectors, and this is reflected in the way it gathers information from taxpayers. Because the property rental market is such a critical issue in current public discourse, I see considerable potential merit in better understanding its structures and operations. The report recommended that Revenue should consider publishing rental income statistics for companies, and this has been accepted by Revenue. The report also recommended that Revenue consider amending its taxpayer returns to include details of individual rental properties, including, for example, a unique property identifier such as the eircode. The final recommendation proposed that Revenue should also consider requiring caseworkers to record the yield from compliance activity by source – for example, rental income – and to collate this data. These two recommendations have not been accepted by Revenue for reasons set out in the report.

I now invite Mr. Niall Cody to make his opening statement on behalf of the Office of the Revenue Commissioners. As set out in the letter of invitation, Mr. Cody has five minutes in which to do so.

I thank the Cathaoirleach for the opportunity to make my opening statement. I understand that today’s meeting is focused on the 2024 account on the receipt of revenue of the State, the 2024 appropriation account, and chapters in the Comptroller and Auditor General’s 2023 and 2024 reports on the accounts of the public service, as well as matters relating to the MV Matthew.

In 2024, Revenue collected total gross receipts of €153 billion, including €31 billion in non-Exchequer receipts collected on behalf of other Government Departments and agencies. The net Exchequer receipts, of €107 billion, were up by almost €20 billion on 2023.

Up to the end of November this year, Exchequer receipts collected by Revenue were €97 billion which, when you exclude the state aid receipts, is up over 8% from the same point last year. Revenue's gross expenditure in 2024 was €581 million. Revenue had 6,805 staff serving at the end of 2024, with €394 million, or 68% of Revenue's gross expenditure in 2024, related to pay. The other main item of expenditure was on information and communications technology, ICT, which accounted for some €88 million in 2024.

Chapter 18 of the 2023 report examined the systems and procedures Revenue has in place to facilitate the assessment and timely collection of carbon taxes. The examination team made no findings. In 2023, the year to which the chapter relates, Revenue collected almost €935 million in carbon tax receipts. In 2024, it was €1.07 billion, and to the end of October 2025, €961 million. Most carbon tax receipts come from the carbon component of the mineral oil tax which, over the past three years, has accounted for approximately 86% of all carbon tax receipts.

Chapter 19 of the 2023 report focused on the systems and procedures Revenue has in place for the collection of the sugar-sweetened drinks tax. The tax operates as an excise duty and is administered on a self-assessment basis. In 2024, Revenue collected €30.5 million from the sugar-sweetened drinks tax, with €25.4 million collected in 2025 to date. The chapter made two recommendations, both of which were agreed, with remedial actions arising implemented in full.

Chapter 20 of the 2023 report reviewed Revenue's approach to monitoring and managing taxpayer compliance and focuses on the measures Revenue has in place to assess, detect and deter non-compliance. Since 2018, Revenue's structure is one of a segmented case base that seeks to align resource allocation to risk. Where tax risks are identified, Revenue's compliance intervention framework provides a consistent and graduated response to taxpayer behaviour, ranging from extensive opportunities to voluntarily correct mistakes up to the pursuit of criminal sanctions for cases of serious tax and duty evasion.

In 2024, Revenue completed over 272,600 audit and compliance interventions, which yielded €591 million. Revenue secured 148 summary convictions, as well as 20 criminal convictions for serious tax evasion and published 74 settlements in the list of tax defaulters. In 2025, to date, Revenue has completed almost €197,000 audit and compliance interventions, which yielded €476.7 million. The chapter makes two recommendations, both of which were agreed, with remedial actions significantly advanced and very much part of Revenue's ongoing programme of systems development.

The plastic bag levy was introduced in 2001 with the main purpose of reducing the consumption of single-use plastic bags by influencing consumer behaviour. The progressive reduction in the use of the levy on plastic bags is reflected in the trend of annual levy receipts, which peaked at €27 million in 2008 and had fallen to €1.4 million by 2023. Chapter 21 of the 2023 report reviewed the assessment and collection of the plastic bag levy in respect of a specific taxpayer. I trust the committee will understand that due to my legal obligation under section 851A of the Taxes Consolidation Act 1997, which is to uphold taxpayer confidentiality, it is not possible for me to discuss matters pertaining to a specific taxpayer.

Chapter 22 of the 2024 report focused on the taxation of income derived by specific cohorts of taxpayers operating in the rental sector. It is the responsibility of those in receipt of rental income, in line with the principles of self-assessment, to ensure that the rental income is reported to Revenue in their annual tax return. As outlined in the chapter, across the years 2017 to 2023, Revenue carried out just over 21,000 compliance interventions on taxpayers who operated in the rental sector. The total yield from these interventions was just over €230 million. In 2024 and the year 2025 to date, Revenue carried out a further 2,500 compliance interventions with an associated yield of €43.1 million. The chapter makes three recommendations, one of which was agreed. Of the recommendations not agreed, the first relates to broader policy matters that fall outside Revenue's remit, while the second relates to the recording of yield from compliance activity under the specific income stream giving rise to the yield. I am satisfied that the current approach to recording compliance intervention outcomes adequately supports effective reporting of the compliance activities and aligns with the basis on which tax liabilities are calculated.

The committee has also expressed an interest in matters relating to the MV Matthew. Following on from my correspondence with the committee on this matter in September 2025, the advance briefing provided for today's meeting includes up-to-date information and cost figures reflecting the current position in relation to the MV Matthew. I assure the committee that the disposal of this vessel is a key priority for Revenue and I am happy to discuss this matter further at today's meeting.

To conclude, I wish to take this opportunity to thank all Revenue staff for their professionalism, dedication and commitment. I again draw the committee's attention to section 851A of the Taxes Consolidation Act 1997 and my obligation to uphold taxpayers' confidentiality. Subject to this constraint, I am happy to answer the committee's questions.

I thank Mr. Cody. I note that we will suspend the meeting for about ten or 15 minutes at 12 noon and resume shortly afterwards. I now open the floor to members and the lead speaker today is Deputy Murphy, who has 15 minutes. All other members have ten minutes thereafter. If time permits, I will allow members back in for a second round of questions. The floor is Deputy Murphy's.

I thank the Cathaoirleach. To start, I understand that Revenue operates on the basis of different divisions. There are five national operational divisions, which are effectively the ones pursuing tax compliance with different types of individual and companies. There are large corporates, high wealth and financial services, medium enterprise, business and personal divisions. Could Mr. Cody give me a rough estimate of how many staff are working in each of those divisions?

The personal and business divisions both have around 1,000 staff. The large corporates division is probably something around 300. The high wealth and financial services, HWFS, division has slightly less than the large corporates division, LCD, and the medium enterprise division probably has around 550.

Okay.

They are approximate and I can give the actual figures. They are to scale.

That is useful. That gets to what I am interested in there, which is the large corporates division. Large corporates make up heading towards 20% of our total tax revenue, I think, but they only make up 10% of the staff. Could Revenue do with more there?

When we restructured, we realigned our structure from four geographic regions in 2018. We always had a large corporates division but we felt at that time that the scale of the large corporate sector and the complexity had grown so much that the geographical regional system was no longer appropriate. At that stage, the large cases division looked after large corporates plus high-wealth individuals. We divided those two but we have increased the resources for large corporates and high wealth by, I would say, 60% to 70% in that period. That was purposeful. In the large corporates and high-wealth individuals divisions there is a high level of principal officer and assistant principal officer grade. The personal division has a significant number of clerical officers and executive officers. What we are trying to do is make sure we are adequately resourced to address those issues.

If you take large corporates, it is organised on a sectoral basis. We would have a fairly constant review of the large corporate sector by dedicated resources to give that overview of what is happening. There are areas in the financial services sector that are structured in such a way legally that there is very little tax.

Certainly, to this committee, and, to be fair, to the Comptroller and Auditor General over the years, we would have indicated that we had a concern that we just did not understand enough-----

How they were structured.

-----about funds and all the rest of it. As a result, we set up a dedicated branch. At the time, we were very concerned to understand what was happening in the economy.

Yes.

I remember dealing with parliamentary questions about how many audits we did on section 110 companies. The figures looked really small as a result of the fact that an audit is not the appropriate intervention because those companies are structured in such a way as to not have a tax liability. In 2015, we published our first detailed analysis of corporation tax and every year since, we have published detailed analyses of corporation tax. The Deputy can see-----

A related question is that, obviously, advance tax decisions were something the public became aware of because we had the Apple case. The essence of that case was two advanced tax decisions from Revenue saying to Apple that these companies will be treated in a certain way. That, ultimately, was found to constitute substantial state aid. Are there advance tax decisions with other multinationals? I am obviously not asking Mr. Cody to name them, but how many of these advance tax decisions are there?

We give rulings on the interpretation of the legislation to businesses on request on full disclosure of the facts of the case. At the time of the Commission opinion, one of the things we agreed to do was publish the number of opinions. In our annual report, the publish details of the number of opinions. In the most recent annual report, 80 opinions were listed. We publish that information every year - I think we are doing so this week - and we issue a tax and duty manual to practitioners. One of the other agreements is that each ruling is timebound up to a maximum of five years-----

And they have to be renewed.

-----and they have to reapply. What we do is give a view of what the legislation that is in place means.

I will move on. One of the striking things is that the number of audits and investigations has been coming down significantly. In the years immediately after 2016, there were over 6,000. By 2021, the figure had dropped to just over 1,000. In 2023, it was under 1,000. The yield has not come down to the same extent it came down initially, and then it comes back up. What explains that significant reduction?

It goes back to our realignment of our structures. One of the particular concerns I have with the geographic regional system is that if we count the number of audits, we can do ten audits of a small business, which would take time. We probably would not do one of a large corporate in the same period. Therefore, what we did was structure our resources to deal with the risk.

So it is more focused now, effectively.

It is more focused on both identifying risk, which applies across the case base, but also complexity. If there is an IT systems mistake in a large entity in relation to VAT, that can lead to a significant liability. Such a mistake would not indicate any attempt at evasion. It is down to the structure and the resources. We have been the subject of various reports by the staff of the Comptroller and Auditor General would look at the 20 biggest audits in a year. That is always a really interesting chapter for everybody.

I will move on. In relation to the chapter on rental taxation, there was what seems to have been a very effective project focusing on landlords with three or more properties. Between 2024 and 2024, the division carried 884 interventions in total. Around 46% of the cases - almost half - yielded more than €7 million in tax interests and penalties. On average, each one was about €18,000. First, were those randomly chosen or where they picked because there were some red flags that suggested they might, effectively, have been overestimating their expenses?

The bulk of our interventions are risk based.

That was the case with that targeted project as well.

And that was the case with that.

Why did the Office of the Revenue Commissioners wind this programme down?

I would not say we wound it down. We have actually been engaged over the past two years in very intensive work in relation to landlords. I have a particular concern, and the team will know this, about trends in the past while around fairly egregious practices in the rental sector. We have had a number of really intensive interventions, some of which led to considerable court action and legal challenges. They are complex and difficult. The Deputy knows what-----

I agree with all that, and I am happy it is happening. Why would Revenue wind down that project or the other one? Why would it not keep going with both?

We do not really refer to it as winding down the project. All our interventions are based on risk. What we will focus on at any particular time is more specific and more high-risk cases. Again, it is a matter of-----

So-----

-----managing our resources across all the activity-----

Yes, but let me just quote from the Comptroller and Auditor General's report, which states, "In 2020, Revenue's personal division commenced the targeted projected on landlords that ran until 2024." Is that project continuing?

It is, yes.

It is.

There is significant work by the personal division on landlords, and also looking at the-----

The project is not finished; it is continuing.

One of the biggest risks for the personal division in the context of non-compliance relates to renting. Most of the taxpayers in the rental income sector are primarily PAYE, non-business trading-----

Yes.

-----and have properties. However, some of the more egregious ones are not dealt with by the personal division at all.

Just so I can be clear, is it wrong to describe this as a project?

I would not consider it a project now; I would say it is a core part of personal division risk work.

Was there a project from 2020 to 2024?

All these efforts start as projects to see what the risk is and what we can learn. The principal officer in charge of the compliance area is very much dedicated to implementing the learnings the branch has had. It was a branch that was very new to compliance activity. In a way, that activity probably was not taking place to the same extent up until that started.

I did not intend to get stuck on this particular issue, but I am slightly confused. The Comptroller and Auditor General was very clear that there was a particular project in relation to the over-declaring of expenses-----

That is new to the personal division.

-----and that that project had ended. I am not clear from Mr. Cody if that is accurate or not. Has that project ended?

That phase of the project. Now, we are engaged in identifying people who have not declared any rental income at all.

Yes, but the focus on expenses is over.

No. When we look at a landlord who is not declaring rental income at all, once we get into the intervention, it is about their income plus their expenses. That becomes a core part of it.

Effectively, Mr. Cody is saying that both sides are included in the way Revenue pursues it now.

Both sides are, yes. We are really looking at-----

Another issue that was raised is the matching of properties. Hundreds of thousands of properties are not matched with the register kept by the Residential Tenancies Board, RTB. Mr. Cody might explain what that means. It means that a landlord is appearing on the RTB register but is not appearing on Revenue's system as having paid tax on the rental income involved.

Not necessarily. One of the challenges in matching names and addresses in Ireland is the unique number. Eircodes became part of the solution for that. We would have had it when we were-----

Mr. Cody does not agree or has rejected the recommendation that landlords should have to submit eircodes.

In our correspondence with the Comptroller and Auditor General, we identified the idea that the Residential Tenancies Board is the competent authority in relation to rental income. Since the report was published, in the context of the Department of housing having talked about landlords reporting the actual details of tenancies, it has emerged that the Residential Tenancies Board is to introduce a public rental price register-----

Yes. If the RTB did that, it would make the Revenue's life much easier.

As a tax man, and I have been one all my life, I would like absolute, complete information on every transaction that takes place. We need legislation to give effect to that, however. There is a whole other constituency that will talk about the burden on business.

At the moment-----

We have a data-sharing agreement with the RTB. The chief executive of the board has talked about its new IT system and enhancing the sharing of date with us. We are really interested in anything like that. The only problem is, and the Deputy knows this very well, there are rogue landlords who are neither on the RTB register nor ours.

I was coming to that next.

We are actively looking at them, and it is a really challenging matter.

I thank Mr. Cody.

I thank Deputy Murphy and call Deputy Byrne.

The witnesses are all very welcome. I start with nitrous oxide. Revenue and Customs officials have said on "Prime Time" that this is being brought into Ireland at scale by organised crime gangs and that it is being used nationwide. While the smaller cartridges do, ostensibly, have a use in catering, Mr. Thomas Talbot from the Revenue's criminal investigation team has said there is no legitimate use for the larger canisters. Organised crime is making money on the back of society. I have been highlighting this issue for years. There is growing evidence of the use of nitrous oxide in communities, and the number of instances of harm caused by the misuse of nitrous oxide are becoming increasingly apparent. I do not think the Government is taking this as seriously as it should.

We have a Bill before the House to provide for the regulation of the sale of nitrous oxide. Basically, it would ensure that nitrous oxide would be regulated for commercial use only. It is similar to legislation in the Netherlands. The Bill would give the Garda powers to seize canisters from those lacking the appropriate licences. Is this something the Revenue would support?

We are very active in relation to nitrous oxide. The Deputy is right. Mr. Thomas Talbot will be on "Prime Time" tonight talking about it. When we were spoken to about doing the programme, I asked if it would be broadcast on the night before our meeting with the committee. That would have been better. We are very serious about this issue.

It is costing huge money. Revenue has already spent €1.6 million on destroying what has been seized. What was seized probably represents only a fraction - let us be real - of what is out there in our communities.

There was a Supplementary Estimate brought forward a few weeks ago. One of the costs listed was that relating to the disposal of nitrous oxide. It needs to be disposed of safely, and this is a real problem. Ms Kennedy has been talking to her French colleagues. They have the same problem. There is a legitimate use for this product, but it is a fairly limited, curtailed one. Anyone who walks around the city will see the discarded canisters. I will not say they are everywhere, but I certainly see plenty of them at weekends.

Yes.

They are a real challenge. The fact that something has a dual use means it is more difficult for us to deal with it because that will always be the justification.

If it was regulated for commercial use-----

We would support regulation.

Great.

But there is a challenge around how it is defined.

Yes. My colleague Deputy Mark Ward will be appearing on that show tonight as well. He is leading the way on this. The programme is quite timely. I appreciate Mr. Cody's response.

I am going to move on because we are tight on time. Between 2020 and 2023, more than €1.3 billion in funding increases from carbon tax rates was allocated by the Department of public expenditure to specific programmes across five other Departments. The report states that only 61% of that sum could be verified as having been spent on targeted schemes and programmes. Of the €28 million in carbon tax funding, €13 million was deferred between 2020 and 2023. It was subsequently used on programmes that were not targeted for funding from the increases relating to carbon tax. What measures have been taken to ensure that the funding from carbon tax increases is spent only on the targeted schemes and programmes it is supposed to be spent on?

I will defer to my colleague from the Department.

I am not an expert on that particular issue. There is a climate action group in our Department. I will have to get the Deputy a detailed note on what is being done. The Comptroller and Auditor General said it is a matter for a policy decision. I will get a specific note on it.

Despite this matter being referred to in the report, it is not possible to get an answer in respect of it. Has Revenue liaised with the Government on this matter directly at all? Has it made any intervention?

We have no role in this regard. Our job is to collect the money involved. We then pass it to the Exchequer and the Government. The chapter sets out very well the position in relation to it. We have no role in relation to it, however. As with any other tax receipts we get, it is passed on to the Exchequer. Our role stops there.

I appreciate that. However, in Mr. Cody's opinion, should or could it be flagged as false accounting or misappropriation by the Government? A carbon tax is being inflicted on hard-pressed people and then the money is not being spent where it is supposed to be spent. Does the Revenue have any opinion on that?

I do not have an opinion on that. I have no role in relation to it.

No problem. Does the Department have any opinion on that?

It is a policy issue.

Fair enough. I am sure this matter will be picked up by my colleagues later.

The upkeep of the MV Matthew is costing a fortune. The amount of money involved is exorbitant. Nearly €10 million has been spent in less than two years. In other words, a startling amount of more than €100,000 a week. Mr. Cody is on record as saying the disposal of the vessel is a priority for Revenue, but that seems to be proving problematic. Has Revenue considered scuttling the vessel? There is precedent in that regard with the MV Shingle. The latter was moored in the port of Drogheda, my hometown, at certain times from 2014 until it was eventually sunk off the coast of County Mayo in 2024. If consideration has not been given to scuttling the MV Matthew, have we had a look at what price it will fetch in a sale or whether there would be a net profit or loss for the taxpayer?

We have provided up-to-date information to the committee in relation to the MV Matthew. It is worthwhile to go over how the ship ended up in our control. The MV Matthew is a very large ship that was used for the smuggling of 2,250 kg of cocaine into the State. It was taken out by Revenue, the Army Rangers, the Navy and the Garda. This was the largest seizure of cocaine ever in the country and one of the largest ever in Europe. The seizure of the vessel was unprecedented. This vessel was bought by an international crime gang to import a consignment of drugs, and 2,500 kg is a lot of cocaine. In the context of the size of the ship, the consignment took up a very small portion of it. This happened in September 2023.

I am aware of the background of the matter. I do not mean to cut Mr. Cody off, but I am tight on time.

This is really important because there is a concern, and it has been expressed to us, regarding the ship being expensive to keep and there being regulatory requirements we have to meet. There is a concern that if this happens again, we will be deterred from seizing vessels because of the scrutiny involved and on foot of people's concerns. I just want to put on record that if something similar happens, we will do exactly the same thing.

In relation to the context, Deputy McGrath knows very well the size of the ship and the safekeeping of it. To ensure safety - environmental and ecological - and due to the impact on Cork Port, we have had to crew the vessel. There is a crew of 13 permanently on this vessel. The vessel has to be kept operating. Until December 2024, it was part of evidence for the court proceedings and then the Special Criminal Court gave us approval to put it up for sale. Before we could sell it, we had to have it properly registered. The engagement with the Panama flag authorities was protracted, partly because the owners of the vessel had not carried all the regulatory requirements.

What I am trying to get out of Mr. Cody here, with respect, is-----

I was involved when we seized MV Shingle.

I appreciate that.

We had that for 14 years.

I think Mr. Cody is trying to avoid the question. Is there a figure that he has determined for what the sale of this vessel might bring in? Is it going to bring in a profit?

Absolutely not.

The State is going to see a further loss after the sale of this ship. Is that the expectation?

Yes.

That is really all I am trying to find out.

There are probably two possibilities when we get to the end of the regulatory requirements. It will either be disposed of to be scrapped or there is a slight possibility it might be sold as a going vessel. If it is disposed of for scrappage, it will actually cost us more to scrap it.

It will be more than the figure of nearly €10 million.

Yes. It is only going to cost more than it has cost to date, and really that is a matter of how long the rest of the regulatory requirements take. They are going to take at least a number of months.

I thank Mr. Cody. I am out of time.

Before we move to the next speaker, I have to step out to attend another meeting with the Taoiseach, which is being held in a room beside this one. Deputy McAuliffe had hoped to be back but, unfortunately, he is caught in the Chamber. With the agreement of members, I will ask Deputy McGrath to take the Chair.

I welcome the witnesses. Mr. Cody said the carbon tax is not the remit of Revenue. Between 2020 and 2023, Revenue collected €1.36 billion. The Government tells people when it is raising carbon taxes that they will be ring-fenced to help reduce carbon emissions. I want to go into the nitty-gritty of that. If Revenue does not have responsibility for the carbon tax, who has responsibility for it? Is it Mr. Nolan's Department?

The Department of public expenditure has policy responsibility.

That Department has responsibility, so that is Mr. Nolan's job. What is his job again?

I am on the Revenue Vote.

A figure of €1.36 billion has been allocated to target carbon emissions. Is that correct?

No. I do not allocate that.

What does the Department do with that money? Where did the €1.36 billion go?

That goes into the Exchequer and then it is-----

It goes into the Exchequer.

It goes into the Central Fund, yes.

I thought it was supposed to go for carbon tax.

No, sorry. It is collected by Revenue, as I understand it, and it is put into the Central Fund. Then, when the annual Estimates are put to the Dáil and approved the relevant Departments have a specific share-out of the carbon fund to specific projects. The Department of public expenditure has a metric for the allocation of the carbon fund to things like, say, fuel allowance, energy poverty efficiency, the aggregate housing upgrade scheme, peatlands restoration, the just transition fund, greenways, urban cycling and the continuation of electric vehicle purchase grants.

One of the ones that I noticed was carbon tax. An allocation of €1.5 billion was supposed to be made to incentivise farmers to farm in a greener and more sustainable way. That was part of the previous programme for Government. Does Mr. Nolan know whether that happened?

I cannot give a specific answer on that. There is something like 50 Votes and I think those-----

The previous programme for Government advertised that €1.5 billion would be allocated to incentive farmers to be greener. I want to know if that happened.

I cannot give a specific answer.

Mr. Nolan cannot tell me. Who would I ask in that case? That person should be here because we want to know where the money is going.

To explain, Revenue collects the money.

Yes, I know Revenue collects the money.

That comes into the Central Fund.

Yes. Revenue collected this additionality, €1.36 billion, between-----

Over four or five years.

-----2020 and 2023. I want to know where it put that money. It was supposed to be spent on green projects.

As I understand it, that was collected over the last five or six years. That then comes into the Central Fund as Government revenue. In order for it to be spent on the objects for which it is intended, it has to be voted through individual Votes for the relevant Government Departments and public bodies. The Deputy mentioned farming. I suspect that has probably been voted through the Vote of the Department of agriculture.

We will need to get representatives of the Department of agriculture in to ask them questions. Is that what Mr. Nolan is telling me?

The Department of agriculture would be responsible for money that is voted under its Vote. I suspect that it is the Department but it would only answer on that particular aspect. With other Departments, for example, there are things like the fuel allowance-----

How much money did the Department of agriculture get?

I do not have that immediately to hand.

What is Mr. Nolan's job again? Does he not allocate money between each of the Departments?

No.

So what is Mr. Nolan's job?

It is the Government that actually allocates the money. What happens is the money comes in from Revenue and goes into the Central Fund but all public moneys have to be voted by the Oireachtas.

Mr. Nolan has come in here today to explain to us where the money is going. Is that correct?

Yes.

Now he cannot tell me where the money is going. I want to know for the farmers because they were told that €1.36 billion collected between 2020 and 2023 was going to be used to target and make farmers more green. That has not happened.

My specific responsibility is actually for the expenditure for the Revenue Commissioners but-----

The €1.5 billion for agriculture was actually between 2020 and 2025.

Yes.

What we reported was that in the first four years, €110 million had been allocated to the Vote for agriculture but all of that was not spent on the green schemes, as expected.

Yes.

I think €60 million of that was returned to the Exchequer.

How much was returned?

It was €60 million out of €110 million.

Out of €110 million allocated, €60 million was returned that was not allocated to the specific target measures.

A further €4 million was carried over into 2024.

Who is in charge of that or who has oversight in respect of that €60 million that was not spent?

Obviously, the Department of agriculture because it received the €110 million. It is accountable for the spending of it or for where it fails to be spent.

Yes.

The more general point that is coming out of this is that with the ring-fencing, or semi ring-fencing, of the money that was collected for carbon transition purposes and so on, effectively that system is failing to ensure that the money is spent for the purposes intended. It is a regularity problem. In terms of the purpose for which it was collected, to a significant degree it is failing to be delivered.

Mr. McCarthy is saying that the money being collected is just going back into the general taxation fund.

Exactly.

It is not actually targeting anything green.

That is the point, yes.

We will have to bring the Department of agriculture in to see what is going on.

On capital acquisitions tax, an exemption from paying capital acquisitions tax applies where someone inherits or receives a gift of a certain heritage, including houses. This exemption has been applied to over €30 million worth of property since 2016, saving a small number of people €4.4 million in taxes. Why would that happen? Most people are liable to pay capital acquisitions tax but people with heritage properties do no not have to pay it. Is that what is happening here? Maybe somebody can explain it to me.

The legislation exempts it. There are certain conditions in the legislation. I had not expected to be questioned on the issue and will get back to the Deputy before the meeting is over. I will get the detail.

Does Mr. Cody have a list of the relevant houses, the houses which were exempt? That can be provided for me.

There are details-----

Is that information open to the public? Can the public see who has to pay a tax and who does not?

There are details published in relation to the capital acquisitions tax heritage receipts every year. I had not anticipated a question about it but I will have the detail before the meeting is over.

That would be great. I thank Mr. Cody. I will move on to Maltese pension transfers. Is it legal to transfer a pension that has reached a standard fund threshold to another state? Is there a justifiable reason why people would do that? I have seen suggestions that people could transfer their pensions to Malta and would not be taxed. Does Revenue investigate that?

There are rules around the transfer of pensions between various member states. There have been a number of transfers in respect of Malta that are subject to examination.

Are investigations ongoing at the moment?

Interventions are ongoing at the moment

Interventions.

Yes. "Investigation" has a particular meaning in relation to tax inquiries that usually involve criminal acts. We prefer to use the term "intervention", which covers our compliance interventions.

How many interventions are going on?

There are somewhere in the region of 35.

What size of pensions would they be?

I do not have the detail of the specific size of-----

Perhaps Mr. Cody could give me the detail of those 35 cases that are being investigated.

I will, subject to taxpayer confidentiality.

Yes. I am not asking for the names specifically.

I know.

I just want to see.

We talked earlier with Deputy Murphy about our structure. We have a branch in high-wealth individuals looking specifically at pension and pension compliance, and compliance with the legislation. It is very active.

Going back to the carbon tax, I want to put on the record that it is not acceptable that of the money allocated for those target measures for the carbon tax, only 61% has been accounted for. Am I correct?

No. Everything has been accounted for. There is what is described generally as the hypothecation of tax, a tax collected for a specific purpose. The system that is used to dispose of that and to spend that money is not achieving, demonstrably, the effect that was intended.

Would the Government not be doing something about that to ensure that people's taxes are going to the correct places?

They are being allocated in the correct way-----

It is not into the right-----

-----but it is not actually being delivered and the money is then being taken back.

Does the Comptroller and Auditor General think that is acceptable?

It is not really for me to say whether it is acceptable or not. I am reporting the fact that it is not happening as intended.

I thank all the witnesses. Before I begin with the witnesses from Revenue, I would like to clarify a matter with the Comptroller and Auditor General. In respect of the vessel we discussed, there is nothing in the reports he has compiled whereby he has given an adverse comment about or been critical of, from a value-for-money basis, how the Revenue has maintained its asset. Is that a fair assessment of the report?

That is true. I have not drawn attention to that expenditure.

To close this out a little bit, if I understood Mr. Cody correctly, he wanted to make it clear, presumably to the people trying to smuggle drugs into this country, that notwithstanding any purported criticism of how this seized vessel is being managed from a cost perspective, it is not going to deter the Revenue from catching drug smugglers coming into this country. Is that the point Mr. Cody is trying to make?

It absolutely is. Even our colleagues in the Army rangers who were authorised as customs officials for the day of the raid - and it was an excellent operation - wondered to us if it would deter us from doing the same again. We told them that it absolutely would not deter us. We have never had to dispose of anything like this before. There are things we would do a little differently. We are reviewing what we are doing. I hope we will manage to dispose of the vessel in the first half of next year and at that stage we will carry out a detailed review of every aspect to see what we could do better and could not do better. We would be quite comfortable if the Comptroller and Auditor General wanted to do a review of the whole exercise when it is concluded.

Is it the intention of Revenue to ask the Comptroller and Auditor General to audit how it has managed the vessel? It is not the only agency in Europe-----

Absolutely not.

-----that seizes drug vessels. Presumably other states have seized drug vessels and are dealing with similar issues. What lessons have been learned from those observations?

Ms Kennedy is the director general at customs and talked to her international colleagues. Some of the costs for these seized vessels that would put our €12 million in the ha'penny place.

That is absolutely the case. There are a number of reasons vessels would be seized. The numerous sanctions imposed by the EU on Russia is one of the reasons. My German colleagues seized MV Eventin, an oil tanker that was a part of the Russian shadow fleet which came into German waters. Since March 2025, Germany has had to maintain that vessel. Not only does it have to crew and berth it, and pay for its running, it is also full of oil so, from an environmental and hazardous perspective, the Germans are trying to determine how to take the oil off that ship.

The Italians have seized a number of super yachts from Russian oligarchs under the sanctions. One of those is costing €30,000 a day to maintain. In the US, some of the yachts seized under the sanctions packaged are costing over €7 million per year at the moment. There are significant seizure expenses. We have seen the success of the Criminal Assets Bureau. It is important that we take out the product and the societal impact of the product on the country and the expenses of the country. An academic research paper from 2000 stated that in one year, class A drugs in the UK, including Wales, had a societal cost of €13 billion. Cocaine to a value of €157 million, had it come onto the market in Ireland, would have had an impact on justice, criminality, education, absenteeism and child protection. There is a huge societal cost so it is important that we attack those who bring it in where it hurts most, which is in their pockets.

I do not mean the following in a trivial way, but Mr. Cody almost smiles when he thinks back to the seizure of this vessel. It was a record-breaking seizure for the State. From Revenue's intelligence, how often does it feel that vessels of this size are entering Irish water space and carrying such large drug loads? Notwithstanding the success in respect of the seizure in question, we have not seen seizures of vessels of that nature since. Is that correct?

The sense in European law enforcement is that having a ship devoted solely to drug smuggling is a new modus operandi.

Normally, there is a container ship in which drugs are placed, either through collusion with crew members or with the shipping company, but there is a cover load. The drugs are dumped at sea by the mother ship and picked up by a daughter boat. The last big criminal prosecution involved a rigid inflatable boat, RIB. The current MO tends to be fast, high-powered RIBs picking up. It is not clear that all the drugs that come into the State are destined for the Irish market alone.

Would it be fair to say that it does not sound like Ireland is going to be left in a position where we may have to seize a vessel of this size again? Mr. Cody mentioned Russian vessels. Have Russian vessels under sanction entered Irish waters where Customs or Revenue have been alive to that and maybe attempted to seize? Has that taken place?

No, that has not taken place. I think it is unlikely that we will have a direct replica of the MV Matthew operation, but there definitely will be significant bulk tankers that have a cover load. If it turns out that the shipping entity itself is responsible, or has not taken due care, I would not rule out that we may well seize a large-----

Does Revenue feel it is sufficiently resourced, funded and prepared, and interacting sufficiently with the various intelligence agencies that it works with, to respond to an incident like that in Irish waters?

I am very confident that in the joint agency task force, in co-operation with An Garda Síochána, the Naval Service, the Army Ranger Wing, if required, our own resources, our strong interaction with Europol and the Maritime Analysis and Operations Centre (Narcotics), or MAOC(N), in Lisbon, and we have officers working in those-----

I only have a minute left. I want to probe one issue that arose at a previous Committee of Public Accounts hearing that the Department of public expenditure and reform attended. In relation to an issue that we do not need to go into, the Department indicated that it had to pay tax penalties of up to €700,000. How often is it that a Department has to pay tax penalties to Revenue for errors it has made? How often is it that a State agency has had to pay tax penalties to Revenue in recent years?

I do not have the exact figures. It has happened a number of times. Generally, I do not think any case has ever arisen that qualified for the tax publication list. The reality is that their accounts always report on it. We would have regular interaction with Government bodies and semi-State bodies in relation to tax compliance. That sometimes leads to tax, interest and penalties, and sometimes just to tax and interest.

Subject to its rules, would Revenue be able to compile a report for the committee for the last three years on where tax penalties have been imposed on Departments or bodies under the aegis of Departments?

I will certainly write to the committee setting out what I can, subject to taxpayer confidentiality.

I thank Mr. Cody and his colleagues for being here. I want to begin with the area of social media influencers. There was a report this year in the media of a settlement of a combined €3.3 million following an investigation between 2020 and 2025. To clarify, have the taxes been fully recouped by Revenue at this point from any parties involved in that investigation?

The work is ongoing. In that period of time, we would have written what we call a level 1 letter, which is essentially advising them of their requirement. It has been a really interesting project. Obviously, it involved a lot of people who were not hugely familiar with tax obligations, some of them with really significant levels of income and turnover. Our main interest is making sure that people voluntarily comply. That is what drives our activity. If they do not, it leads to an escalation of the intervention. Some of the interventions have led to audits and settlements of fairly significant liabilities. It then becomes an ongoing part of compliance. We have recovered significant amounts in relation to social media influencers.

Due to the legislation in relation to platform providers, we also have to report the payments made. If you are doing it, we will know about it. That is why we encourage people to comply. Interestingly, right now, there is a public consultation by the Department of Finance and ourselves on how to tax platform providers in relation to money that flows through them. It focuses on withholding taxes and trying to modernise the reporting system to ensure that people are paying the right amount at the right time so they do not end up with significant liabilities. We know of social media influencers - very young people - with significant six-figure sums earned over a short number of years.

Are those liabilities being contested?

No. Generally, they are being paid, but we would prefer if they were paid on time. To go back to Deputy Geoghegan's question, sometimes the interest bill is far more excessive than any penalties. It is really in people's interest to pay tax when it falls due.

I want to ask about the compliance model. It strikes me that it is probably not a black-and-white scenario, and it is often benefit-in-kind, not like the traditional PAYE worker. Is the compliance model under review? How does that process come to fruition for products and gifts received?

We have published comprehensive guidelines on the tax treatment for income tax, capital acquisitions-gift tax and value-added tax in relation to the different issues. I have read some commentary that the actual model is not up-to-date enough, but we have to operate within the legislative framework. I was reading recently about complaints that OnlyFans people were not able to claim expenses for items of clothing, for example. It is a very different model, in that it is all done through social media. We operate under rules around expenses that are wholly and exclusively incurred for the purpose of the trade. There is a lot of case law interpreting that. It goes back through both the UK and Ireland in relation to suits, barristers and wigs. There is a whole range of case law, and there will be more case law. People are entitled to appeal. The Tax Appeals Commission is a legal, semi-judicial forum, independent from us, that deals with technical interpretation. That is always evolving as business models evolve.

I will ask one more question on this issue before I move on. The timeframe for the initial investigation was 2020 to 2025. Is there any intention to be more retrospective than that in terms of going beyond 2020?

This type of business model - I have to be careful with the use of the word “models” - really took off through Covid.

That really changed the nature of the social media model. We are satisfied that there is not a significant arrear issue predating that.

I will move on to the debt management system. It was interesting to read that almost 60,000 referrals made to Revenue in the year were considered, resulting in the collection of over €250 million. That was an increase in referrals of 12,000 from 2023. Will Mr. Cody summarise why he thinks such an increase in referrals was received in 2024?

I really have to go back to 2019, when we rolled out our new debt management system. About November 2019, we were piloting our new debt management system, which was due to significantly speed up our enforcement operation. When Covid happened in March 2020, we suspended all enforcement action. The debt warehouse came in legally in July 2020 and that ran until May 2022. Essentially, normal debt management and enforcement stopped for that entire period. Obviously, as we came out of public health restrictions, May 2022 to probably 2023 was focused on the unwinding of the debt warehousing system. In 2024, we started to reboot the debt management system and that is fully operational now. What happened over 2023, 2024 and into 2025 was a slippage in timely compliance. That was the overhang of the restrictions. Our aim now is to get back to where we would like to be, where people pay tax as it falls due. There is a significant impact. I was reading last week a report on our activity this year through the debt management system and the expectation is that it has led to an additional €109 billion to date this year in recovering debt that was late and not paid. That will continue.

The DAA confirmed to me in a parliamentary question response that it made settlements to Revenue totalling just under €1 million over the past five years. The majority of this was assigned to something called professional services withholding tax rules. In a similar response by CIÉ, it said it had made similar settlements but spoke about IT assets under CIÉ Tours USA. What strikes me as interesting is that CIÉ is involved in the co-operative compliance framework, CCF. Who is party to that? Are semi-States and commercial bodies party to that framework? Is Dublin Airport Authority party to that? Who opts in and out of that framework?

The co-operative compliance framework is available to businesses within our large corporate division and high-wealth financial services, the original large-cases division cases. In 2003, we launched the compliance co-operative framework programme. It is essentially voluntary to entities managed by them and they can opt in or opt. Some groups, including semi-States, have opted in. Then there are a lot of entities in large cases that have not opted in.

Is there a list available of who has opted in? Is that public knowledge?

That is taxpayer information and there is confidentiality. Some of them publish these details-----

Themselves. I read a review that, between 2017 and 2023, those involved were not audited. Their participation in the framework meant that they were not audited. Is that still the case?

What happens with the co-operative compliance framework is that they are not subject to the audit programme, but they carry out intensive reviews of aspects of it. They will all have a compliance meeting and the challenge we have is to ensure those not in the CCF are audited enough. To be in the CCF there is a high degree of transparency. The CCF framework is best practice across all modern tax administrations in relation to large corporates to ensure that we mind that significant amount of money paid by them.

I thank Revenue for being here. I will focus on the MV Matthew. I do not think that will come as a surprise. Revenue has always been forthright and transparent in any correspondence I have had with it and has always replied. I appreciate that. I also appreciate the information provided in advance of this meeting, particularly in appendix 1. The first question I prepared was to ask the witnesses to clarify whether there was currently a preferred bidder in place. Based on what they said, it seems more likely that this ship will be scrapped. Is that the case?

We have been as transparent as we can. There is not a preferred bidder in place but there is definite interest by a number of bodies, provided that all the regulatory requirements are met. We are the interim registered owners. That was finalised with the Panama authorities. There is a final piece to be finalised with them. I want to put on the record the huge support we got from the Department of foreign affairs and the ambassador in helping deal with that. We have another piece of work to do. As the ship is not being used, its classification standard has lapsed and we have to carry out a number of surveys and get reclassified. One of the surveys is taking place today. There are two that have to be completed.

Is that survey of the actual vessel? I have seen locally that there is diving and so on taking place.

What is happening right now is that the hull is being cleaned because it has to be scraped clean to allow it to be taken out of Cork port. The classification of marine safety office has to approve. If we can get those licences and reclassification and the registration authority finalised, we have a number of parties still interested. However, I cannot guarantee that will come to fruition.

I should have said at the outset that this was a tremendously successful seizure by our security forces - An Garda Síochána, the navy and the Defence Forces. That has to be acknowledged. Mr. Cody mentioned that there were questions arising about whether this should happen again. Of course it should. Where I am coming from is just about how the process has been handled, the disposal of the vessel and so on. Of course we need to do this again. It was €158 million worth of drugs seized and eight people sentenced. This was absolutely critical for our security forces. I hope Mr. Cody understands where we are coming from.

This has caused a lot of concern locally. I represent Cork South-Central. This ship has been located at Marino Point for over two years, a couple of hundred metres from the community at Passage West. There have been issues. Obviously, there are the visual impact and noise issues, which I acknowledge efforts have been made to address. This is raising a lot of concern with regard to the duration this ship has been maintained and the cost involved in it. If it is ultimately the case that the ship is scrapped versus sold, will the same requirements in terms of regulatory title legal issues be involved? Are the same standards there?

Regulatory requirements are still required because the ship has to be taken from Cork port. It either has to be taken under its own power, which is likely if it is being sold as an ongoing vessel, or else it has to be taken by tug.

Could Revenue not have taken the decision 12 months ago to scrap it?

We could not.

Revenue had to address title issues and legal issues.

Yes.

It was only in October just gone that the state of Panama gave Revenue preliminary titles, as I understand it.

Yes.

Where were the delays in that? Was it on Panama's side or ours? Why did it take so long to get that title?

I hesitate to apportion any kind of blame. This was a unique set of circumstances and, as I said earlier, the previous owners had not carried out the proper arrangement, which is no surprise.

It is no surprise, given the activity.

One of our colleagues in the Revenue solicitors division must have had 50 meetings on this. He never thought he was going to be employed in the Revenue solicitors and trying to sell a big ship but the engagement-----

Apologies, but I am really caught for time.

I remember signing an affidavit and the Panamanian authorities probably struggled to understand what the Office of the Revenue Commissioners was and how we owned or claimed to own this ship. We had to send details, with the Customs Act, which set out our powers. It has been very difficult and we are still not finished with Panamanian authorities. Their co-operation is essential.

Bringing it back home to the Irish State, Mr. Cody mentioned in his appendix commentary that a broker was appointed in November 2023. It seemed to come as somewhat of a surprise that the courts would require the retention of this vessel for evidential purposes. Why was there a broker appointed in November 2023, which was over two years ago?

We were hopeful that, if the eight people pleaded guilty, this process would be completed-----

I presume Revenue has seized smaller boats in the past in terms of drugs-----

We have seized boats, trucks, cars and other vessels.

Revenue has experience.

Absolutely.

It knows that the courts require them for evidential purposes.

Yes. If the committee remembers the coverage of the MV Matthew and the videos, those eight people were caught red-handed. If they pleaded guilty early, we would have been in a much better position to handle the regulatory requirements. What we were doing was hoping-----

That it would not have to be maintained.

-----that we would not have to have it for two or two and half years.

This is not a criticism. I am just asking questions in relation to-----

I appreciate that. I have been down there and seen it.

Mr. Cody understands where I am coming from.

Totally.

The key question is whether Revenue was fully prepared. As soon as the courts gave it the green light to dispose of the ship because they no longer required it for evidential purposes, was Revenue 100% prepared to proceed with that? Had it undertaken whatever actions it could have at that point in terms of contact with the Panamanian state and so on? Can Mr. Cody give us an assurance that Revenue was fully prepared once it got the green light from the courts?

Once we got the green light from the courts, we immediately put in train steps to try to dispose of it. The last thing I want to do is have the MV Matthew under our care.

I apologise for cutting across Mr. Cody, but the issue of title, for example, only came through two months ago. Had Revenue been seeking that prior to the ship's release?

Our legal advice was that we should not do anything to interfere with title or anything until we were approved by the court. Overhanging us was this idea that defence counsel was in a position that it could carry out an examination of the ship. We did not want to do anything to hinder the criminal process.

The witnesses were under many constraints. I understand that.

We were under constraints, but if there is a next time, there are certain things we would do a little bit differently.

I would love to come to those, but I have a few questions. The bidding process closed in quarter 1 of 2024. A preferred bidder was identified at that time, but that bidder is no longer in place.

There is no preferred bidder in place at this point.

That is because the legal, technical, title and regulatory issues have taken so long.

Yes. That bidder is not gone, but it is not a preferred bidder at this stage. Interestingly, when we did our original tender process, we had three different interested parties, but when we carried out due diligence, we were concerned about the use that ship would have been put to if it had been sold to them. The MV Shingle, which Deputy Byrne mentioned earlier, was involved in a significant seizure of cigarettes. The registered owners tried to claim it back from us. We told them they could not have it back.

With regard to the drugs seized, which was a substantial quantity, I presume Revenue also had to store those during the court proceedings.

They were under the care of the Garda.

Does Mr. Cody know what the cost of the storage of those drugs was?