Ireland’s Co-operative Compliance Framework: €350m LCD Threshold Explained

Revenue eBrief No. 233/25 (8 December 2025) updated Tax and Duty Manual guidance on the Co-operative Compliance Framework (CCF) for Groups managed by Large Corporates Division (LCD) and High Wealth & Financial Services Division (HW&FSD). The headline change: the group turnover threshold for assignment to those divisions is now €350 million (previously €190 million), and the former €18 million group tax threshold has been removed.

CCF remains a voluntary, trust-based programme. It is not automatic membership of LCD/HW&FSD — Groups must apply, meet compliance criteria across Irish entities, and commit to ongoing self-reviews, an annual risk review meeting, and advance consultation on major restructurings. Certain sector-specific cases continue to be managed in LCD/HW&FSD regardless of turnover.

Participants typically receive a dedicated case manager, a reduced level of Level 2 interventions in the ordinary course, an agreed annual risk review plan, and a streamlined path for corporation tax and VAT refund claims. Non-CCF Groups in the same divisions route through general divisional channels and remain on the standard intervention programme.

Obligations are real: meet filing and payment duties, run ongoing self-reviews and tell Revenue about material errors or under-declarations, complete agreed risk reviews on time, and keep Revenue informed of economic or sectoral shifts. Revenue or the taxpayer can exit if trust breaks down. Formal contracts are not required; acceptance is confirmed by letter.

Excluded categories still apply — for example certain Section 110 companies — so eligibility should be checked against section 3.3 of the manual before investing in an application pack.

Raising the LCD/HW&FSD turnover gate from €190m to €350m (and dropping the separate tax-yield gate) repositions which Groups sit in large-case management and therefore which Groups can even apply for CCF. Finance leaders approaching that scale should model when consolidated group turnover will cross €350m, including acquisitions, and plan tax control frameworks early rather than scrambling after a divisional transfer letter.

A Tax Control Framework — documented ownership of tax risks, controls, and escalation — is central to CCF readiness. Transfer pricing, customs, and excise each have specific CCF touchpoints in the manual; multinational Groups should align TP documentation calendars with the annual risk review cycle.

Applications must cover the entire Irish Group: you cannot put some Irish companies in CCF and leave others out. Exceptional PE cases owned outside the Irish Group are treated carefully in the manual and usually sit outside CCF even if considered for entry of the Irish Group.

Confirm whether your Group is (or will soon be) LCD/HW&FSD-managed under the €350m rule or via sector assignment. If newly eligible and not yet contacted, ask your LCD/HW&FSD contacts about CCF application timing.

Stress-test self-review routines, ROS filings, and disclosure protocols against Code of Practice expectations. Build a living tax-risk register that a dedicated case manager could walk through at an annual meeting.

Keep books, VAT packs, and corporation-tax working papers export-ready. FinnAccountings helps Ireland and UK finance teams organise bookkeeping and tax prep drafts with Chartered Accountant insight before your Chartered Accountant (Ireland) or ICAEW/ACCA adviser signs off filings — start a free trial to tighten controls ahead of any CCF application. Cross-read our Ireland ViDA e-invoicing Phase One briefing if you are also preparing for November 2028 domestic e-invoicing.

For Ireland VAT process readiness, see VAT Services Ireland and the free VAT calculator. Large Groups watching global minimum tax should also review our Ireland Pillar Two filing guidance alongside this CCF update.