The recently published annual report of the Tax Appeals Commission ("TAC") for 2024 offers valuable insights into the impressive performance of TAC.
Notwithstanding increasing levels of complexity, TAC closed more appeals than it received for the sixth year running, resulting in the lowest number of appeals on hand since its establishment.
The Chairperson of TAC recognised that “[t]he 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”. This aligns with our experience in practice.
2024 Statistics
The key statistics for 2024 are as follows:
- 1,711 appeals, valued at €355 million, were closed in 2024. This represents a 38% drop in appeals on hand from 2023.
- Of the 1,711 appeals closed in 2024, 595 (or 35%) were resolved by settlement. These settled cases represented a total of €193 million tax in dispute, 54% of the total amount of tax in dispute in the matters closed in 2024.
- 1,281 appeals were received by TAC in 2024, valued at €207 million. This is a decrease in value from 2023, when 1,156 appeals valued at €613 million were received.
- 280 hearings were scheduled in 2024 (59 of which were held remotely) valued at €390 million.
- 180 determinations were issued in 2024 in relation to 220 appeals valued at €34 million.
- Corporation tax appeals were significantly the highest value appeals closed in 2024. With 89 appeals closed valued at €193 million.
Preparation is Key
The timely and efficient administration of the tax appeals process by TAC means that taxpayers are often called for hearing within very short timelines, often within 12 months. This efficient timeline, combined with the increasing complexity of tax law matters under consideration, means that taxpayers need to start preparations for the hearing date as early as possible. In order to make preparations for hearing as effective as possible, taxpayers should ensure that systems are in place to gather and retain relevant contemporaneous factual evidence which supports all material transactions undertaken.
Looking Ahead
TAC’s annual report notes that 15 appeals with a value of €417 million were received in January 2025. When compared to the appeals received in 2024 with a total value of €207 million it would appear that 2025 is likely to be another busy year for TAC. This demonstrates the continued confidence taxpayers place in TAC as an effective forum for resolving (by TAC determination or settlement) complex tax disputes efficiently and confidentially.