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The Irish Tax Appeals Commission (TAC) has recently published its 2024 Annual Report, providing an insight into the activities and trends in its area of responsibility. TAC is the first appellate level forum in Ireland for appeals against Irish tax assessments. Highlighted below are some of the key points arising from the report and our take on associated trends.
Key statistics
Case statistics
Introduced in 2016 and replacing the Office of the Appeal Commissioners, the TAC is responsible for administering tax appeals across all tax heads ranging in complexity and quantum, and is one option open to a taxpayer disagreeing with a Revenue decision or assessment.
On its inception, the TAC took on a significant number of legacy appeals (appeals made directly to Revenue prior to establishment of the TAC, of which there were 1,157 at 2016) and pre-establishment appeals (appeals made to the Office of the Appeal Commissioners, of which there were 289 in 2016). The TAC has made steady progress through this caseload: reducing in 2024 from 192 to 82 and 15 to 9, respectively. This progress is impressive when one also considers that an additional 1,281 new appeals were filed in 2024.
We note a total of 711 cases on-hand at the end of 2024, a significant reduction of 38% on the 1,141 appeals which had been on hand at the end of 2023. The number of appeals scheduled in 2024 was lower than 2023, and the quantum of appeals scheduled decreased significantly (from €1.4bn in 2023 to €355m in 2024). The TAC report notes that the legal issues arising in appeal cases are increasingly complex, with the impact of treaties and European directives to the fore in cases. The duration of the hearings ranged from a half day to three weeks, with twice as many hearings taking between two and three weeks, when compared to 2023. Undoubtedly, this trend of increasingly complex appeals is likely to continue into the future.
Quantum, case complexity and value
The quantum in dispute in relation to appeals received in 2024 totalled €207m. The 711 cases at hand at the end of 2024 were valued at €383m. During the year, the TAC stated 11 cases to the High Court (down from 26 in 2023).
Settlement
280 hearings were scheduled for hearing in 2024, a decrease on the 441 cases scheduled for hearing in 2023, with 99 cases (35%) settling prior to hearing.
Increased use of technology
The Commission continues to utilise remote hearings and case management conferences (CMCs) in order to progress appeals and increase accessibility and equality for the public in accessing the appeals process. In 2024, 59 hearings and 13 CMCs were scheduled remotely. There was a very significant 64% decrease in remote hearings held since 2023.
The TAC moved in 2023 to a paperless office and now relies on digital records only. The new case management system has reduced the timelines for closure of appeals.
Conclusion
Under a wide variety of metrics, 2024 marked a transition towards increased modernity and efficiency for the TAC, with a significant reduction in the number of cases on hand, with the lowest number of cases on hand since the establishment of the TAC.
Since its establishment, the TAC has now closed almost 13,000 appeals involving a quantum of over €7bn.
For more information on this, please contact Paul Fahy, Partner and Head of Tax, Cian Ryan, Associate, or any member of A&L Goodbody's Tax team. This article was prepared with assistance from Tom Anders, Trainee Solicitor.
Date published: 23 May 2025
