The Revenue Commissioners have discovered that a "substantial" number of persons or entities had transactions or dealings with Ansbacher Cayman Ltd other than the 120 names listed in the recent Ansbacher report, the High Court was told yesterday.

Mr James Connolly SC said that, notwithstanding the Revenue's efforts and use of its statutory powers, there was still a number of codes and Ansbacher accounts without names, the beneficial ownership of which had not been established.

"The Revenue are suffering information deficits and are unable as yet to fully investigate the matter of Ansbacher and related accounts because of the incompleteness of the information which they have obtained," he said.

Mr Connolly, for the Revenue, said that section 22 of the Companies Act envisaged inspectors' reports being utilised in evidence in civil proceedings.

He also argued any duty of confidentiality which a banker owed to a customer was overridden by the duty to co-operate with the inspector.

In an affidavit, Mr Donnachadh MacCárthaigh, principal inspector of taxes in the special projects team, said that since October 1999, the Revenue has been conducting an investigation into the tax affairs of taxpayers who were deposit-holders in respect of Ansbacher accounts.

As a result of Revenue inquiries and investigations, he had formed the view that many Ansbacher account holders were taxpayers who had failed to comply with the provisions of the Taxes Acts.

Ms Noreen Mackey, one of the inspectors, in an affidavit, said that to disclose information over and above that already contained in the report and appendices would amount, in the inspectors' opinion, to a violation of the understanding/obligation as to confidentiality under which they performed their functions.

During the investigation, the inspectors interviewed or obtained documents and information from 200 companies and individuals.

It would be impossible to remember each and every instance where an undertaking as to confidentiality was given, particularly where it was given orally either before or just after an interview, Ms Mackey said.