Over the years, tax officials throughout the Revenue Commissioners were left in little doubt there was simply no appetite at the highest levels of the organisation to take on the banks.
Every proposal put forward by diligent and disillusioned staff suggesting some means to close in on the obvious widescale abuses across the financial sector was firmly rejected. More than one tax inspector has told the committee, the banks were always "off limits".
The most obvious signal was the failure to issue instructions to Revenue officials to inspect the declaration forms used to open non-resident accounts. This power had been incorporated in the 1986 Finance Act upon the introduction of DIRT but a directive - SIM 267 - was subsequently issued from the Chief Inspector of Taxes office telling staff to await further instructions before using this power.
For 12 years there were no instructions. Last week there were suggestions this was largely due to circumstances beyond the Revenue's control with indications the Revenue was taking its cue from the Minister for Finance who feared an outflow of capital if the power was exercised.
It now seems clear though the board of the Revenue itself was responsible for not allowing its staff to inspect these declarations.
Evidence from two senior tax inspectors from the investigations branch highlights the onerous constraints placed on officials when it came to dealing with financial institutions.
Mr Patrick Donnelly reminded the committee that tax inspectors took an oath when they were appointed, undertaking to administer the tax laws fairly but were effectively prevented from doing so because of the special position conferred on the banks. The decision not to inspect the non-resident declaration forms held at the banks was a serious setback to the investigation branch when it came to gather information on various taxpayers, according to Mr Donnelly. "When you came up against it, it was very frustrating. You just had to live with it." He added it was difficult to carry out his job in a fair way when a large section of tax evasion - bogus non-resident accounts - was ring fenced.
In response to an inquiry from Mr Jim Mitchell, Mr Donnelly said that as frustrating as the directive was, he had never made direct representation to his seniors to have instructions issued. "I was fairly disgruntled with it but did nothing concrete about it. I regret that I didn't take a challenge but it's difficult to challenge given the weight of resistance to it above."
Another bone of contention was the clear preference of the board of the Revenue to seek out settlements with taxpayers where arrears were discovered rather than to initiate prosecutions where other individuals and financial institutions may have been complicit in concealing those funds.
"There was a settlement culture rather than prosecution culture," he explained. One case which had proved very frustrating was the board's decision in 1984 not to prosecute bank officials at the Bank of Ireland in Tipperary who opened some 166 bank accounts for a taxpayer and his wife throughout the Republic.
The case had been settled with the Revenue collecting some £125,000 from the taxpayer, who in turn gave five pages of evidence to the inspectors on how the bank officials had facilitated the tax fraud. According to his account, a number of bank staff called to his home one evening with up to 200 forms to be signed by himself and his wife to allow them to open up the bank accounts for them.
The board decided not to refer the matter to the DPP.
Former Revenue chairman Mr Cathal Mac Domhnaill, who held this position for much of the period being investigated by the committee, has begun to explain what he did and didn't do in relation to bogus non-resident accounts.
His contribution has gotten off to an inauspicious start with the chairman establishing that Mr Mac Domhnaill had given incorrect information to a Dail Committee of Public Accounts hearing last year. At that stage he told the committee that in 1991 the Revenue had made approaches to all of the financial institutions in relation to the collection of DIRT. This has since been corrected. Mr MacDomhnaill said approaches were made to specific institutions.