What To Know If Appealing A Tax Assessment

Introduction

There has been a marked increase in enquiries initiated by the Irish Revenue Commissioners ("Irish Revenue") in recent years, with a resulting increase in the number of amended tax assessments being raised against taxpayers by Irish Revenue.

There are a number of reasons underpinning this increase in Irish Revenue activity, including:

• Irish Revenue has bolstered its resources, both in terms of headcount and technology / data analytics expertise and systems. This is most pronounced in the context of transfer pricing ("TP") where Irish Revenue's TP branch has significantly increased its resources in recent years;
• recent State aid investigations conducted by the European Commission have changed the audit environment and there is, in general, an increased focus on the tax affairs of multinationals; and