Tax officials say complexity of legal issues shows the impact of EU rules and treaties
The commission’s annual report reveals that in the first two weeks of January alone, it received 15 appeals with a total disputed value of €417m.
The commission is the statutory body that hears and adjudicates on tax disputes. Appeals can be sought by both individuals and companies.
Last year, the body closed 1,711 appeals with a disputed value of €355m. It noted that for the sixth year in a row, it closed more appeals than were received, reducing the number to 711 by the end of 2024 from 1,141 a year earlier. The number of open appeals at the end of 2024 was the lowest number since the body was established in 2016.
Marie-Claire Maney, the commission chairperson, said the increasing complexity of the legal issues in appeals was a continuing trend in 2024, “with the impact of European treaties and directives to the fore”.
Appeals are typically launched against decisions by the Revenue Commissioners. The disputed amounts can range from less than €100 to more than €1bn. The names of the parties taking the appeals are not published.
Revenue saw ‘unprecedented’ levels of activity through its online services during 2024
High-profile cases during 2024 included a transfer pricing case involving a US software development firm. The commission redacted the disputed amount of tax involved.
It rejected transfer-pricing adjustments that had been sought by Revenue related to the supply of services by an Irish subsidiary to its American parent. It specifically concerned share-based awards granted by the parent firm to the Irish subsidiary.
Meanwhile, Revenue has confirmed in its newly published annual report that total gross tax receipts for 2024 reached €152.9bn. That included €30.9bn of non-Exchequer receipts collected on behalf of other government departments and agencies, and other EU states. Net tax receipts for the year were €107.1bn.
It noted that one of its key priorities in 2024 was helping businesses to exit the Covid debt warehousing scheme in a “viable manner”. The scheme was established to help companies get through the pandemic by being able to park their tax debts.
Revenue said that more than 93pc, or €3bn, of the debt included in the scheme at its peak in January 2022 has now either been settled in full or secured under phased payment arrangements.
“Just over 7,000 businesses that availed of the scheme failed to engage with us to formulate a plan to pay their warehoused debt,” Revenue said.
“The debt owed by these businesses, which amounted to just over €100m at that time, was subsequently removed from the warehouse,” it added. “Normal collection and enforcement proceedings applied to this debt thereafter.”
Revenue saw “unprecedented” levels of activity through its online services during 2024. There were 25.4 million logins to its MyAccount service. It also processed 60.5 million customer declarations and received €136.4bn in electronic payments.
In 2024, Revenue undertook more than 272,000 audit and compliance interventions, which yielded €591m for the Exchequer, and conducted another 46,000 appraisals. It also closed 256 tax avoidance cases, yielding a further €46m.
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