Owners of bogus non-resident accounts have been warned that those who do not avail of the Revenue's voluntary disclosure scheme are likely to be caught.

The warning was issued by tax partner with Farrell Grant Sparks, Mr Declan O'Hanlon, who said some bogus account holders may be considering not complying with the scheme because of recent comments from the Institute of Taxation.

The account holders have been lulled into "a false sense of security" by the institute's recent advice that the Revenue scheme could be open to constitutional challenge.

"Since that advice was given we have had a number of queries from other professional advisers that indicate that some of these account holders may be considering not complying until the legal position is cleared up. Such a move by these account holders would be unwise."

An estimated 20,000 to 50,000 bogus account holders have until November 15th to come forward.

Holders of bogus accounts would not be any worse off if they came forward, Mr O'Hanlon said.

Under the scheme account holders will have to pay the full tax owing as well as interest and penalties, capped at 100 per cent.

They are guaranteed freedom from prosecution or publication.

"If they don't comply they will almost certainly be detected and made to pay the full tax, penalties and interest, which could be multiples of the amount of tax owing. In addition, they will face publication and the likelihood of prosecution," he said.

"We have also detected from our seminars that some of the bogus non-resident account holders are labouring under a delusion that the Revenue haven't got their account details.

"All of the evidence to date indicates that the banks are co-operating with the Revenue in clearing up bogus non-resident accounts and are supplying and will supply details of all such account holders."

Mr O'Hanlon said account holders should be under no illusions as to the Revenue's detection powers.