The Revenue Commissioners warned in 1999 that residency rules relating to taxation could be open to abuse, according to a programme on RTÉ television last night.

The Prime Time special on RTÉ One quoted a Revenue report, which said that some individuals claimed to be non-resident "yet, in reality, live here".

The programme also claimed to have a "top-level report from February 1999", which said that tax partners advised their clients to use a range of devices to avoid taxation.

According to the programme, this document said: "Experience has shown that partners employ a wide range of avoidance devices, and their behaviour is in turn mirrored in the behaviour of the high-net-worth individuals they advise."

However, during the programme, Minister for Finance Brian Cowen denied residency rules were being abused by wealthy individuals.

"I think it's working quite well," he told the programme.

He said the residency rules were in line with international trends.

The Revenue last night declined to comment until they had an opportunity to view the whole programme.

According to the programme, the Revenue chairman Frank Daly has warned the Department of Finance that asking for information on various tax reliefs is likely to prompt opposition from tax advisers.

Mr Daly is quoted as saying that seeking extra information would result in "concerns to tax practitioners who feel they are over burdened already".

He adds: "Once we go down this road, there will be likely opposition from this quarter, including representations to the Minister and we should not underestimate this."

The programme also points out that because JP McManus and John Magnier are not resident in the Republic, their recent windfall from the sale of shares in Manchester United will not be taxed here. The programme claims this will result in the loss of €25 million to the Irish Exchequer.