Tax Disputes & Enquiries
As the leading contentious tax practice in Ireland, A&L Goodbody consistently acts on the most significant tax disputes and enquiries, frequently having an international dimension.
Our team comprises experienced lawyers from our Tax and Litigation practices in collaboration with specialists from our other practice areas. We represent clients at all stages of domestic and international tax dispute and enquiry processes, including on tax authority queries and audits, liaison with Competent Authorities and proceedings before the Irish Tax Appeals Commission (TAC) and the Courts.
With increased tax authority scrutiny and cross-border information sharing requirements, we believe strongly in the value for clients in engaging legal advisors as early as possible. We bring a litigation mind-set to matters from the outset and are particularly adept at applying clear and commercial advocacy throughout to ensure our clients achieve the optimum outcome as quickly and efficiently as possible.
Representing and advising clients across all tax heads domestically and internationally, our work broadly encompasses:
- Irish Revenue enquiries and aspect queries
- Irish Revenue audit defence
- Voluntary disclosures
- Tax assessments – validity and settlement
- Irish Revenue powers of investigation
- Tax litigation – TAC, Irish and EU Courts
- Mutual Agreement Procedures (MAP)
- Advanced Pricing Agreement Procedures (APA)
- International Exchange of Information Requests (to include Irish Revenue powers)
- Cross-border tax investigations
- Transfer pricing disputes
- State Aid investigations
US Pharma Group
representing and advising with respect to judicial review proceedings before the Irish High Court and a TAC appeal concerning a tax assessment associated with a disposal of IP rights.
representing and advising a number of multinational corporations with respect to disputes with the Irish tax authorities concerning transfer pricing arrangements.
Multinational Pharma Group
representing in a TAC appeal concerning the VAT treatment of rebates made by our client to private health insurers. The TAC recently ruled in favour of our client in this matter and it is under appeal by Revenue to the High Court.
representing and advising with respect to a dispute with the Irish tax authorities concerning the denial of a corporate tax deduction for finance related costs.
requesting Competent Authority assistance under the Ireland/USA double tax treaty relating to transfer pricing assessments raised by the IRS.
Multinational Pharma Group
representing and advising with respect to matters relating to the Mutual Agreement Procedure under the Ireland/Germany double tax treaty and the EU Arbitration Convention.