Specialist advice on complex tax matters, Revenue interventions, tax appeals and disputes.
Book a consultationWe advise private clients, business owners and companies on complex tax matters where the technical position, the amounts at stake or the potential consequences require specialist advice.
Our work ranges from independent tax technical opinions, second opinions and due diligence reviews through Revenue enquiries, audits and investigations to contested assessments, appeals before the Tax Appeals Commission and court proceedings.
We are frequently engaged where a taxpayer or their existing adviser requires an independent assessment of a difficult tax position, where Revenue has challenged a transaction, relief or interpretation, or where a disagreement has developed into a formal dispute.
Where appropriate, we work alongside solicitors, barristers, accountants, valuation experts and other professional advisers.
We establish the facts, examine the relevant legislation and identify the technical and evidential issues that are likely to determine the outcome.
This may involve reviewing a proposed transaction, an existing tax position, a Revenue assessment or advice already received.
For significant or technically difficult matters, we provide independent tax technical opinions and second opinions.
We assess the strengths, weaknesses and risks in a position so that important decisions can be made with a proper understanding of the tax consequences.
Where Revenue has intervened, we test the underlying tax position rather than simply accepting Revenue's analysis.
We reconstruct transactions, review documentation, examine the evidence and determine whether the tax, interest or penalties being asserted are properly due.
How and when a taxpayer responds to Revenue can materially affect the outcome.
We consider disclosure options, statutory protections, penalty exposure, publication, procedural rights and the wider dispute strategy before substantive positions are adopted.
We represent clients in correspondence, meetings and negotiations with Revenue and throughout contested tax matters.
Where agreement cannot be reached, we prepare appeals to the Tax Appeals Commission and, where appropriate, challenges on points of law or judicial review proceedings.
The instinct is often to explain, answer questions and try to talk the problem away. Poorly considered letters, undocumented conversations or inconsistent explanations can strengthen Revenue’s position and weaken your own.
By the time specialist advice is sought, evidence may already have been created, positions conceded and opportunities lost.
Some of the questions that commonly arise when Revenue intervenes, a tax position is challenged or an independent technical view is required.
Obtain advice before making a substantive response. The type of intervention, its scope and its timing can affect disclosure opportunities, penalties, publication and the way in which the matter should be managed. We normally review the Revenue correspondence and relevant background before advising on the appropriate response.
Potentially. Irish tax legislation and Revenue's Code of Practice provide mechanisms through which taxpayers can disclose tax defaults and potentially obtain significantly reduced penalties and protection from publication or prosecution. Timing and the nature of the disclosure can be critical. A disclosure which qualifies at one stage may cease to qualify after Revenue takes further action.
For a significant intervention, we generally recommend obtaining advice beforehand. Revenue may ask detailed questions about transactions, records and events which occurred several years previously. Statements made during meetings can become important evidence later in the intervention. We prepare clients for Revenue meetings and attend where appropriate.
No. Revenue's interpretation is not determinative of the law. We independently examine the legislation, relevant case law, Revenue guidance and the underlying evidence before advising whether Revenue's position should be accepted, negotiated or challenged.
Yes. We are regularly engaged to provide an independent view on significant or technically difficult tax matters. A second opinion can be particularly valuable where substantial tax is at stake, the legislation is unclear, a relief depends upon detailed conditions or different advisers have reached different conclusions.
Yes. We undertake technical and due diligence reviews of proposed and completed transactions. The objective is to identify technical weaknesses, evidential gaps and potential Revenue challenges before they become a dispute. Where appropriate, we can recommend additional documentation or other steps to strengthen the tax position.
Many Revenue assessments and determinations carry a statutory right of appeal to the Tax Appeals Commission. Strict procedures and time limits can apply. We assess the technical basis for an appeal, identify the evidence required and develop the case to be presented to the Commission.
Yes. We advise on and prepare tax appeals from the initial notice of appeal through to hearing. This can include developing the technical arguments, preparing written submissions and documentary evidence, identifying and preparing witnesses, and working with specialist tax counsel where appropriate.
The appropriate next step depends on the circumstances and the nature of the issue. Where a dispute concerns a point of law, there may be a route to challenge the determination through the courts. We assess the determination, the legal issues involved and the merits and risks of taking the matter further.
A tax appeal generally concerns the substantive tax position — for example, whether an assessment is correct or whether a particular relief or tax treatment applies. Judicial review is different. It is concerned with the legality of a decision or decision-making process rather than simply whether the correct amount of tax has been assessed. In appropriate cases, judicial review may arise where Revenue or another decision-maker is alleged to have acted outside its legal powers or followed an unlawful decision-making process.
In certain circumstances, yes. Publication does not, however, automatically follow every Revenue settlement. The nature of the default, the amount involved and the availability of statutory protections all matter. Disclosure and settlement strategy should therefore be considered at an early stage.
Yes, although most Revenue interventions are resolved without criminal proceedings. Where deliberate tax evasion is suspected, potential criminal exposure changes how the matter should be handled. Coordination between tax advisers, solicitors and counsel, together with careful consideration of legal privilege and how information is provided, may become particularly important.
Whether you need an independent opinion before completing a significant transaction, have received a Revenue intervention letter or need to challenge an assessment or decision, early specialist advice can materially affect the outcome.