:format(webp)/f/122463/1200x800/abb3b8ec50/maximising_benefits_for_full-time_family_farm_workers.jpg)
PAYE Disclosure Opportunity offered by the Revenue Commissioners
Farmers who rely on contractors, relief staff or seasonal labour must review their arrangements after the Supreme Court’s landmark Karshan (Domino’s Pizza) ruling on worker status otherwise face fines, penalties and publications for failure to operate payroll taxes on salaries paid.
The decision, delivered in October 2023, enshrined the five-step test for deciding if someone is an employee or self-employed for tax purposes.
:format(webp)/f/122463/2800x1867/69cb3e25bb/tax_implications_receiving_gifts.jpg)
Opportunity to Put Things Right
Revenue has now given employers a chance to correct mistakes made in 2024 and 2025.
Where a worker should have been on payroll, businesses can make a disclosure to Revenue before 30 January 2026.
Crucially, these corrections will be treated as a technical adjustment only.
That means:
No tax-geared penalties
No fixed penalties
The correct PAYE, USC and PRSI will be due
Credit will be given where workers already paid tax under self-assessment
PRSI records will also be created to protect workers’ entitlements.
What This Means on Farms
The ruling affects a wide range of common arrangements in farming. If people work under your direction, use your equipment, and take no financial risk themselves, Revenue is likely to view them as employees. It's clear, if you have anyone working for you and no payroll is in place, you need to review the position now.
Examples include:
Locum vets hired during calving or lambing
Drivers for silage, slurry or hedge-cutting contractors
Seasonal workers
Relief milkers and farm relief staff
Mart or co-op staff such as clerks, weighbridge operators and yard hands
:format(webp)/f/122463/620x414/8657b8d9bc/business_tax_strategy_2.jpg)
Act early
Disclosures must be made before 30th January 2026. After that date, any misclassifications found by Revenue will be treated as a failure to operate PAYE, USC and PRSI – with full interest and penalties applied.
Support from ifac
At ifac, we welcome Revenue’s practical approach. However, the responsibility now rests with farmers to act quickly. Reviewing contracts, calculating liabilities and preparing disclosures takes time, and mistakes could be costly if deadlines are missed.
Our teams can guide you through every step – from reviewing your arrangements to submitting the disclosure to Revenue.
The message is clear: act now, don’t leave it until the last minute
Contact our team
Contact a member of our expert team and find out how we can support you.