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ARTICLE · 29 DECEMBER 2025

Disclosure Opportunity To Regularise Misclassification Of Self-Employment

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On 11 September 2025 the Revenue Commissioners issued a press release announcing an opportunity for businesses to correct payroll tax issues for 2024...

IrelandTax
Mark Barrett
Mark Barrett
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Introduction

On 11 September 2025 the Revenue Commissioners issued a press release announcing an opportunity for businesses to correct payroll tax issues for 2024 and 2025 arising from the bona fide misclassification of workers. Businesses that acted in good faith, relying on the case law and guidance available prior to the Supreme Court judgment in Revenue Commissioners v Karshan (Midlands) Ltd t/a Domino's Pizza [2023] IESC 24 ("Karshan"), but that may have misclassified employees as contractors are encouraged by Revenue to take this opportunity to regularise their tax affairs.

Employers will be permitted to enter into settlement terms in respect of the relevant payroll tax issues, without imposition of interest or penalties, where they engage with Revenue before Friday, 30 January 2026, on the issue. Any necessary adjustment to income tax, USC or PRSI liabilities due in respect of 2024 and 2025 will be treated as a "technical adjustment" under the Code of

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