Travel & SubsistenceCompliance Checklist
Every rule, record, and threshold your business needs to meet for Irish Revenue. Based on Section 114 TCA 1997 and the master guidance in TDM Part 05-01-06. Use the interactive checklist below to audit your own compliance.
Work through the checklist below to identify compliance gaps.
The Three Conditions for Tax-Free Treatment
Every T&S reimbursement must satisfy all three simultaneously
Irish Revenue treats travel and subsistence reimbursements as tax-free only when three strict conditions are met. Fail any one of them and the entire payment becomes a taxable benefit-in-kind, subject to PAYE, USC, and employer PRSI. The consequences of getting this wrong include grossed-up tax assessments where every €1,000 paid to an employee costs the employer approximately €2,309, plus penalties of up to 100% of the underpaid tax and potential publication on Revenue's quarterly tax defaulters list.
Temporarily Away from NPW
The employee must be temporarily away from their Normal Place of Work in the performance of duties. Travel between home and the NPW is always private commuting — any reimbursement is taxable regardless of distance.
Necessarily Incurred
The travel expenses must be necessarily incurred in performing employment duties. This is the "wholly, exclusively and necessarily" test from Section 114 TCA 1997 — stricter than the self-employed test which drops the "necessarily" requirement.
Subsistence Attaches to Travel
Subsistence expenses must attach to qualifying travel, supported by long-established tax case law. Meals and accommodation only qualify when linked to a qualifying business journey — you cannot claim subsistence without the underlying business travel.
Round-Sum Allowances Are Always Taxable
Revenue's position is unequivocal: a weekly or monthly flat payment "irrespective of expenses actually incurred" — for example, €500 per month for expenses — is fully taxable and subject to PAYE deductions. Car allowances paid in lieu of a company car are equally fully taxable. The payment must track actual business travel at approved rates.
Normal Place of Work: Decision Helper
The NPW determination is the foundation of the entire T&S framework
The Normal Place of Work is "the place where the individual normally performs the duties of her/his office or employment." This is always a question of fact determined case by case. The employer's registered address is not automatically the employee's NPW — two employees of the same company can have different normal places of work. Getting this wrong means every subsequent reimbursement is potentially taxable. See Revenue's NPW guidance.
NPW Quick Assessment
Answer the questions below to determine the likely NPW classification. This is a guide only — final determination is a question of fact.
Does the employee normally perform duties at the employer's office/premises?
Ireland Has No "24-Month Rule"
Unlike the UK's HMRC, Ireland has no statutory time-based definition of a temporary workplace. Revenue applies a practical framework instead: domestic subsistence at any one location is limited to six months, with overnight rates tapering progressively after 14 nights. The focus is on whether the employee is genuinely "temporarily away" — not on a fixed calendar threshold.
The "Lesser Of" Rule
When a business journey starts from home rather than the NPW, the tax-free amount is limited to the lesser of the distance from home to the temporary location or from the NPW to the temporary location. This prevents employees from profiting by starting a journey from a home further away than their office.
The Complete Compliance Checklist
26 checks across 5 categories — tick each item to track your compliance
This checklist covers the mandatory requirements from Revenue's TDM Part 05-01-06. Work through each category and tick items your organisation already satisfies. Your progress is saved automatically in this browser so you can return to it.
Normal Place of Work
0/5 complete
Journey Records
0/6 complete
Rates & Reimbursement
0/5 complete
Record Retention & ERR
0/5 complete
Special Categories
0/5 complete
The Six Mandatory Data Points Per Journey
TDM 05-01-06, Chapter 1.3 — omit any one and Revenue disallows the claim
Revenue specifies six data points that must be captured for every T&S claim. Without all six, Revenue will disallow tax-free treatment. With the introduction of Enhanced Reporting Requirements from 2024, Revenue now has real-time data to identify patterns and anomalies, so incomplete records are flagged faster than ever.
Employee Identity
Name and address of the employee or director
Date of Journey
The specific date on which the travel took place
Business Reason
Why the journey was necessary (client meeting, site visit, etc.)
Kilometres Travelled
Actual distance driven or method of transport used
Route Details
Starting point, destination, and finishing point of the journey
Reimbursement Basis
Overnight stay, day rate, mileage band, or vouched receipts
Retention Period
Electronic Records Are Acceptable
Revenue accepts electronic records under Section 887 TCA 1997, provided:
- Data integrity is assured from the time the record is first generated
- Records can be displayed in an intelligible format with ready access
- Records are maintained continuously — not created retrospectively
How Subsistence Rates Taper Over Time
Domestic and international tapering schedules side by side
Revenue limits how long you can claim subsistence at full rates at any single temporary location. Domestic overnight rates taper after 14 nights, while international rates taper monthly. After six months at any one location, employer must apply to Revenue to agree a continued rate. Understanding these tapering thresholds is critical for audit-proofing longer assignments.
Domestic Overnight Tapering
Distance thresholds: Day subsistence requires 5+ hours absence at 8km+ from home and NPW. Overnight requires the location to be 100km+ from both (50km in exceptional circumstances).
International Assignment Tapering
Circular 07/2017 governs foreign rates. Rates are country- and city-specific, published in local currencies. These rates have been unchanged since April 2017 and are widely considered outdated.
Rules by Worker Type
Employees, directors, and the self-employed each face different rules
The T&S regime is not one-size-fits-all. Standard employees follow Section 114, directors face the same rules with heightened Revenue scrutiny, and the self-employed operate under an entirely different statutory test. Critically, sole traders cannot use civil service flat rates — a distinction that catches many small business owners.
Key point: Employers must maintain a satisfactory recording and internal control system. The employee must have borne the cost before reimbursement.
Revenue Penalty Framework
Revenue's penalty structure is designed to encourage voluntary disclosure. The difference between an unprompted qualifying disclosure and waiting for Revenue to discover the issue can be the difference between a 10% penalty and a 100% penalty on the underpaid tax — plus interest at approximately 8% per annum. Where PAYE has not been correctly operated, Revenue collects on a grossed-up basis: every €1,000 paid net to an employee costs the employer approximately €2,309 including tax and employer PRSI.
| Behaviour | Penalty (No Disclosure) | With Disclosure | Interest Rate | Publication Risk |
|---|---|---|---|---|
| Deliberate (no disclosure) | 100% | 75% (prompted disclosure) | 0.0219%/day (~8% p.a.) | Yes, if €50,000+ in tax |
| Deliberate (unprompted disclosure) | 10% | N/A | 0.0219%/day (~8% p.a.) | No (if qualifying disclosure) |
| Careless (significant — >15%) | 40% | 5% (unprompted disclosure) | 0.0219%/day (~8% p.a.) | Yes, if €50,000+ in tax |
| Careless (not significant) | 20% | 3% (unprompted disclosure) | 0.0219%/day (~8% p.a.) | Unlikely |
| Insufficient care (record-keeping) | €3,000 per year | N/A (fixed penalty) | N/A | No |
Grossed-Up Assessment: What It Actually Costs
When Revenue finds PAYE wasn't operated correctly, they don't just charge the tax that should have been withheld. They treat the net payment as a gross amount and calculate upwards.
This is before penalties and interest are applied. A deliberate breach adds up to 100% of the underpaid tax, with interest at ~8% p.a. compounding from the original due date.
The Five Mistakes Revenue Finds Most Often
Based on Revenue audit findings and TDM warnings
Mislabelling Remuneration as Expenses
Revenue warns that where payments that are really remuneration are labelled as expenses, they "will consider whether there is any element of fraud or neglect involved or whether a Revenue offence may have been committed." This is the most serious finding possible.
Incorrect NPW Determination
Post-pandemic, many employers wrongly treat home as the NPW for hybrid workers. Others reimburse home-to-office commuting as "business travel" for remote workers. Revenue is firm: the office remains the NPW for anyone splitting time between office and home.
Round-Sum Allowances Without Payroll
A flat monthly payment irrespective of actual travel (€500/month "for expenses") is always fully taxable. Car allowances in lieu of a company car are equally taxable. These must go through payroll with PAYE, USC, and PRSI deducted at source.
Inadequate Journey Records
Without the six required data points per journey, Revenue will disallow tax-free treatment for the entire claim. Tax advisors describe auditing business mileage claims without proper log books as "shooting fish in a barrel."
Failing to Tax Excess Over Civil Service Rates
Any reimbursement above civil service rates must either be supported by vouched receipts or be taxed through payroll. Paying above the approved flat rate without receipts or payroll deduction is a clear audit finding.
Legal & Regulatory References
Every source cited in this checklist
Stop Guessing at Compliance.Automate It.
Expense.ie captures every data point Revenue requires, applies civil service rates automatically, classifies vouched and unvouched expenses correctly, and generates ERR-ready reports. Built for Irish businesses by people who understand Irish tax law.
6/6 Data Points
Every journey record captures all six mandatory fields automatically
Rate Compliance
Civil service rates applied with automatic excess flagging
ERR-Ready Exports
Reports formatted and classified for Revenue submission
No setup fees. Cancel anytime. Irish-built for Irish businesses.
T&S Rates
Complete current mileage and subsistence rate tables for 2025–2026.
View ratesPolicy Template
Build a Revenue-compliant travel expense policy with clause-by-clause guidance.
Build policyMileage Log Template
Interactive log validator, best-practice fields, and non-compliance cost calculator.
Get templateERR Compliance
Enhanced Reporting Requirements — timing, filing, and penalties.
Read guide