Tax Appeals Commission received €417m quantum in appeals for two weeks of 2025
Gordon Deegan
The Tax Appeals Commission (TAC) has received 15 tax appeals with a combined estimated quantum of €417 million in the first two weeks of 2025 - more than double the entire estimated quantum of €207 million in appeals received for 2024.
Figures published in the 2024 TAC annual report show that the estimated €417 million in appeals is also €34 million more than the entire €383m quantum in appeals on hand at the end of 2024 at the TAC.
The surge in appeals during the first two weeks of the year has resulted in the Commission revising its 2025 targets, estimating now that there will be a €750 million quantum in appeals on hand at the end of this year.
The figures show that the largest proportion of new appeals last year concerned disputed corporation tax at an estimated €94 million.
The €383 million quantum in appeals on hand at the end of 2024 is down sharply from the €1.7 billion on hand at the end of 2021.
The figures show that last year, the TAC closed out appeals valued at €355 million.
In a breakdown of the €355 million in appeals closed out, the figures show that €193 million of the cases were settled while €122 million in appeals were withdrawn by appellants.
During 2024, the TAC issued 180 determinations concerning a quantum of €34 million.
Of the €355 million closed out appeals, €193 million of the appeals concerned corporation tax.
During 2024, 280 hearings affecting 507 appeals with a total quantum of €390m were scheduled over 456 days. The duration of the hearings ranged from a half day to three weeks.
In her report, chairperson, Marie-Claire Maney said that “for the sixth year running the Commission closed more appeals than it received, reducing the number of appeals on hand from 1,141 to 711, notably a 38 per cent decrease”.
She said: “This marks the lowest number of appeals on hand since the establishment of the Commission. The appeals determined and closed have released back to the Exchequer or the economy €355 million in 2024.”
She added: “The increasing complexity of the legal issues in appeals is a continued trend in 2024, with the impact of European Treaties and Directives to the fore.”
During 2024 the Appeal Commissioners signed 11 cases stated to enable determinations to be appealed to the High Court.
Of the 11 cases stated issued, eight were requested by appellants and three by the Revenue Commissioners.
The report states that despite a request for a case stated, not all cases stated proceed to a hearing before the High Court due to settlement between the parties before or after filing of the case stated or a change in the decision of the party requesting the case stated to proceed to the High Court.
