Ireland HW&FSD Enhanced Compliance Engagement: ECE Pilot to End-2027

On 30 June 2026, Revenue published eBrief No. 111/26 announcing a new Tax and Duty Manual for the High Wealth and Financial Services Division (HW&FSD) Enhanced Compliance Engagement (ECE) Framework. The manual sets out how High Wealth Individual (HWI) taxpayers whose affairs are managed in HW&FSD can engage with Revenue on a voluntary, cooperative footing.

The ECE framework operates as a pilot from the second quarter of 2026 through 31 December 2027, after which Revenue will review it. HWIs are defined as taxpayers whose net asset value is estimated at €20 million or more. Participation does not require a formal agreement — taxpayers may opt in at any stage during the pilot.

ECE has two voluntary elements. First, a Tax Pack Compliance Review lets taxpayers submit backup tax computations and supporting documentation so Revenue can review the annual return in near real time — particularly useful where the year includes exceptional items. Revenue intends to complete that review within about eight months of receiving the pack, and manages it as a Level 1 intervention under the Compliance Intervention Framework so the taxpayer retains the right to make an unprompted qualifying disclosure while the review stays within agreed parameters.

Second, taxpayers may seek opinions or confirmations on significant transactions. Under ECE, HWIs can engage even where the transaction is not complex or unusual — a wider pathway than the general HW&FSD opinion procedures alone. Examples in the manual include share or property valuations, reliefs on disposals, next-generation share transfers, company purchase of own shares, reorganisations, business/agricultural/retirement relief, and inheritance asset movements. Opinions are not given where Revenue considers the arrangement to be tax avoidance.

On 1 July 2026, eBrief No. 112/26 updated Tax and Duty Manual Part 37-00-40a (HW&FSD opinions/confirmations) so section 1 points readers to the ECE Framework procedures for significant-transaction opinions. Outside ECE, Part 37-00-40a continues to set the stricter “complex, unusual, or uncertain” gate for advance opinions, with separate manuals for National Operational Divisions and Large Corporates Division.

For ECE participants, requests go to the relevant branch manager and/or dedicated case manager. Revenue asks for secure channels — MyEnquiries via ROS, the Revenue File Transfer Service, or TLS-enabled email — and will acknowledge receipt. Submit well before the earlier of the return filing due date or the actual filing date for the return that reports the transaction.

Watch for Revenue’s initial ECE communication naming your branch manager and dedicated case manager. If you plan to use the framework, tell Revenue early so resources can be aligned — there is no obligation to reply if you will not participate.

For tax-pack reviews, aim to deliver computations by 31 January in the year after the return was due if you want headroom to self-correct within Compliance Intervention Framework time limits after the review. You may submit the pack as soon as the return is filed; you need not wait for the pay-and-file deadline.

Keep working papers exportable and complete: valuations, relief computations, and transaction memos that map to Form RTS 1A where used. Under ECE, where the transaction is not complex, Form RTS 1A may show “Not Applicable” in the specific-doubt box — still prepare a clear tax analysis for Revenue to review.

FinnAccountings helps Ireland and UK finance teams organise bookkeeping and tax prep drafts with Chartered Accountant insight before you or your Chartered Accountant (Ireland) or ICAEW/ACCA UK adviser reviews and signs off filings. Use a free trial to keep computation packs and transaction files review-ready while your agent engages HW&FSD under ECE — we do not file with ROS or replace your adviser.

Related reading: our Co-operative Compliance Framework €350m briefing for large-case context, and the free tax calculator for high-level Ireland and UK liability estimates only.