The Revenue is rejecting, in the strongest possible terms, the evidence given by AIB about the handling of DIRT on bogus nonresident accounts.
The chairman, Mr Dermot Quigley, is categorically denying there was an amnesty or an agreement that retrospective DIRT prior to 1991 need not be paid. He is reiterating the Revenue Commissioners was misled about the scale of the AIB problem.
These assertions are contained in a 50-page response to the Dail's Committee of Public Accounts of the evidence given by the AIB chief executive, Mr Tom Mulcahy, last week.
But AIB, in its matching document to the committee, strongly restates its case that an effective amnesty was agreed on DIRT liabilities before 1991 and its understanding was that this was known to the Revenue at the highest level.
The absence of any minutes from meetings of the Revenue board at the time needs to be considered in deciding what happened, it says.
In its response, circulated to members of the committee yesterday, Revenue says it does not accept the clear implication in Mr Mulcahy's statement there was an industry-wide "resolution" in the form of an "amnesty" in 1991 for the non-payment of DIRT due before that date. "Neither Revenue's senior management nor the Revenue Board ever approved such an amnesty for AIB," Mr Quigley says.
Instead, the Revenue says its talks with AIB resulted from investigations of taxpayers with accounts at two AIB branches. During a meeting on February 13th, 1991, AIB said it was indicated an amnesty was on offer for pre-1991 liabilities. But the Revenue says this meeting was held to ensure proper procedures were followed at AIB to ensure depositors were not allowed to evade tax.
Dealing with the AIB "contention" that an amnesty arrangement was confirmed in a telephone conversation between an AIB executive and a senior inspector on March 5th, 1991 - a key plank in the AIB case - Revenue responds that its officials have no evidence or recollection of this. The Revenue also argues AIB could not have concluded that such an amnesty would be given.
"Anyone with even a cursory knowledge of the tax system, never mind detailed knowledge of it, would know that an amnesty could not be given in such a manner and without legislation," according to its statement.
Mr Quigley maintains the AIB evidence has tended to obscure the point that "there was an indisputable onus on the bank to pay the DIRT due for all years".
Saying it was not given full information on the scale of the problem, the Revenue says it only obtained the detailed internal audit documents when they were requested from the AIB after disclosure in the Sunday Independent in April, 1998. The Revenue is awaiting further data from AIB.