Tax Disputes & Enquiries: Experience

  • 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.
  • Multinational Corporations: representing and advising a number of multinational corporations with respect to disputes with the Irish tax authorities concerning transfer pricing arrangements.
  • Real Estate Company: representing and advising with respect to a TAC appeal concerning VAT repayment claims.
  • Multinational: 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.
  • Multinational Corporations: 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.
  • Canadian Multinational: advising in respect of a transfer pricing adjustment imposed by the Canadian Revenue Authority and corresponding adjustment pursuant to the Ireland/Canada double tax treaty.
  • US Multinational: representing and advising with respect to a TAC appeal concerning the Irish Revenue Commissioners' refusal to allow a group relief claim.
  • European Multinational: advising the group in settling a significant payroll withholding liability with the Irish Revenue Commissioners by way of protective voluntary disclosure.
  • Various Multinationals: advising in respect of international exchange of information requests under Irish law, EU law, Irish double taxation treaties and the OECD Mutual Assistance Convention, and the application of the Irish Revenue Commissioners statutory powers in this context.
  • Multinational Pharma Group: representing and advising in respect of a TAC appeal concerning the VAT treatment of certain payments made by that pharmaceutical company.
  • Multinational: representing and advising in respect of a hearing before the TAC in relation to the VAT treatment of hire purchase transactions, which resulted in a case stated to the High Court and a resultant change in Irish VAT legislation in favour of our client.