The Revenue team assigned to investigate the Ansbacher deposits has also been told to investigate a tax evasion scheme in Liechtenstein which may have been set up by a Dublin accountancy firm in the 1980s.
In a statement yesterday the Revenue said that "on foot of recent information" it has initiated the inquiry. A spokesman declined to elaborate. RTE has a memorandum drafted in 1984 which outlines the details of how the scheme might operate. It is likely the Revenue also has the document.
Although it lists several individuals and Swiss, UK and Liechtenstein financial advisers and companies - and a linked Dublin-based firm - it is unlikely the Revenue instructed the high-powered team investigating the Ansbacher deposits to investigate the Liechtenstein scheme, unless it had additional information to that in the memorandum.
It is also unlikely the decision to begin the inquiry was made unless the Revenue had reason to believe substantial tax evasion may have occurred. The memorandum indicates that an Irish business figure who was about to sell an asset, was interested in finding ways of hiding at least part of the consideration from the Revenue.
The buyer was US-based and the memorandum's author travelled to Zurich to interview financial advisers about the possibility of the funds being placed in a Liechtenstein trust.
It also details the lengths the scheme's operators would go to to insure the existence of the funds never came to the attention of the authorities here.
The Revenue inquiry will try to establish if the Irish business figure used the scheme and whether any other Irish residents used the same system to hide funds offshore. It is not known if the Dublin firm which effected the introduction still exists.
The memorandum stipulated that persons who established such trusts would never create any documentation in this jurisdiction, so the Revenue inquiry may have to depend on interviews. But documentation may exist, as the 1984 memorandum was obviously produced for reading by person's in this jurisdiction.
The memorandum stipulates that persons who avail of the scheme should not inform the executors of their trusts, "because to do so could create extreme difficulty for the executive". In the event of the trust beneficiary dying, the administrators of the trust would make "discreet inquiries" after they had not been contacted for more than 12 months, and thereby learn of the beneficiary's demise.
They would then contact the "successor in authority", who would most likely be the spouse or the children of the beneficiary, and inform that person of the existence of the trust.
The memorandum states that the funds should never be brought back into this jurisdiction, unless they were "very carefully trickled back", as their sudden arrival might excite the attention of the Revenue.
In this regard the scheme was very different from the Ansbacher deposits where lodgments were often kept in Dublin, and withdrawals could be made through the late Des Traynor.
