647. Deputy Sorca Clarke asked the Tánaiste and Minister for Finance whether the Revenue Commissioners has procedures in place to suspend or withdraw Sheriff enforcement where a taxpayer has made a payment immediately prior to the issue or execution of a Sheriff warrant; whether associated Sheriff costs may be waived in such circumstances; and if he will make a statement on the matter. [59604/26]

648. Deputy Sorca Clarke asked the Tánaiste and Minister for Finance if he has engaged with the Revenue Commissioner regarding the impact of debt enforcement action on otherwise viable small and medium-sized businesses experiencing temporary cash flow difficulties, particularly in the construction sector where delayed payment is common; whether consideration will be given to greater flexibility before Sheriff enforcement is initiated where taxpayers are actively engaging with Revenue Commissioners and making payments; and if he will make a statement on the matter. [59607/26]

I propose to take Questions Nos. 647 and 648 together.

I am advised that Revenue’s clear preference is to always work with taxpayers experiencing cash-flow difficulties and to identify and agree mutually acceptable payment solutions, and to avoid deploying debt collection/enforcement actions. Revenue encourages taxpayers to engage early when payment difficulties arise and has a strong track record of successfully working with individuals and businesses to resolve their payment difficulties.

Taxpayers are afforded several opportunities to address their payment issues and to engage with Revenue to avoid enforcement action. Where current taxes become due in line with statutory deadlines, a request for payment issues shortly after the due date has passed. This request includes details of the tax(es) due and requests payment within a set timeframe. This request for payment also outlines the consequences of continued non-payment and affords the taxpayer a minimum of seven days to engage. In most cases, on receipt of this initial notice, the taxpayer will either make full payment for the due tax or contact Revenue to agree the payment of the tax within a mutually acceptable timeframe, at which point no further action is required.

However, in the absence of taxpayer engagement a further notice is issued in the form of a Final Demand again highlighting the risk of enforcement action and allowing a further seven days for the taxpayer to engage. It is only where there is continued lack of engagement from the taxpayer in response to this Final Demand and after the expiry of the time allowed, that the case is escalated for enforcement action. This approach ensures fairness and a level playing field for most taxpayers who meet their tax obligations by the statutory due dates.

The important message for taxpayers who receive these notices is to engage with Revenue at the earliest opportunity so that a mutually acceptable solution can be found. Where the liabilities are discharged within the prescribed timeframe, or where a payment arrangement is agreed, no enforcement action is taken.

Revenue’s track record in working and supporting business was very clearly demonstrated in 2024 with the closure of the debt warehousing scheme where Revenue worked with businesses to agree flexible Phased Payment Arrangements (PPA) to meet their individual circumstances. The vast majority of the 12,700 PPAs set up to pay warehoused debt are being maintained, with payments of approximately €20 million being collected each month to date. This illustrates the pragmatic and flexible approach Revenue adopted in assisting businesses to exit the warehouse. That flexible and supportive approach continues today in a post warehouse environment.

Revenue acknowledges there may be instances where some taxpayers have temporary cashflow issues and are unable to pay their tax liabilities on time. Revenue’s online PPA facility is an easy-to-use service for individuals or businesses who need to pay tax debt on a phased basis. Once the arrangement is in place, the facility includes several flexibilities to manage temporary payment difficulties that might arise during the term of the arrangement, including options to defer the next payment due or take a payment break of up to six months. These flexibilities are available to businesses in all sectors including those in the construction sector.

Finally, where a PPA is in place to manage outstanding tax debt and scheduled monthly payments are honoured, tax clearance is maintained enabling the business to avail of certain grants and public sector contracts where applicable and ensuring valuable cash flow is maintained to the greatest extent possible.

In addition, I am informed that Revenue does not refer cases to the Sheriff where the payment is fully cleared and brought to account. In certain cases, a payment may have been made by the taxpayer just before the case is sent for enforcement but the payment has not be fully cleared or been brought to account, referred to as crossed payments. This occurred in 532 cases last year, representing just over 0.6% of the 86,516 warrants issued in 2025. These referrals were withdrawn once Revenue became aware of the payment either by internal controls or notification from the taxpayer and/or Sheriff. In such specific cases, Revenue will contact the Sheriff to withdraw the warrant, and the taxpayer will not be subjected to any associated Sheriff costs.

It should also be noted that Sheriffs are Officers of the Court, holding office under Section 12 of the Court Officers Act, 1945, and are independent of Revenue. Their debt collection activities, including seizure procedures, are covered by the Enforcement of Court Orders Act, 1926, as amended. The calculation of Sheriff’s fees and the expenses reasonably and necessarily incurred by Sheriffs for each individual warrant are set down by statute in Statutory Instrument No. 644 of 2005. Any queries on the amount or charging of Sheriff fees should be directed to the relevant Sheriff’s office.