A number of customers of Bank of Ireland's trust company in Jersey are reparing to take legal action claiming the bank exposed them to excessive tax liabilities.

Sources associated with some of these individuals, who would largely be high net worth customers, said they would claim the trusts were set up incorrectly and seek compensation for the additional taxes they now face.

Earlier this year the bank wrote to hundreds of its customers with trusts in Jersey advising them to declare voluntarily potential tax liabilities to the Revenue Commissioners before it begins a full-scale inquiry of the offshore bank.

A Bank of Ireland spokesman said it had not received any statement of claim and that no issues had been raised by these customers.

To date, some 254 Bank of Ireland customers have paid €100 million in back taxes, interest and penalties to the Revenue. One individual paid €7.3 million while 27 paid €1-€2 million.

The Revenue has suggested it may collect up to €600 million from the owners of these trusts.

Disgruntled clients are claiming that the bank failed to establish a separate structure into which the income earned from their funds would be paid leaving them exposed to a potentially higher tax bill.

Most of the bank's customers incurred hefty tax bills because they had used the trusts to evade tax.

The Revenue Commissioners has broadened its inquiries into offshore accounts to Irish Permanent's Isle of Man subsidiary and has made contact with Anglo Irish Bank which also has operations there.

The State's tax authorities have also requested special meetings with the chief executives of Irish financial institutions as part of its inquiry into tax evasion through offshore accounts.

The Revenue does not have the authority to inspect the ledgers held at the offshore subsidiaries of Irish financial institutions but has been gathering evidence from the clearing system in Ireland.

Meanwhile, some customers of Bank of Ireland and the former State-owned ACC Bank, who held bogus non-resident accounts, are expected to initiate legal proceedings against these institutions claiming they were encouraged to evade tax through these type of accounts.

A number of account holders have already begun to seek discovery orders from the High Court to seek documentation from AIB related to the opening of bogus non-resident accounts in the 1980s and 1990s.