Value of disputed tax cases before appeals commission plummets by €2.85bn in 2021

The quantum in disputed tax cases before the Tax Appeals Commission (TAC) last year plummeted by 63 per cent, from €4.5 billion to €1.65 billion.

The commission’s 2021 annual report shows that it closed 1,800 appeals, the highest number since ints formation. The appeals had a combined value of €3.14 billion.

The largest reported settlement last year concerned the disputed €1.64 billion tax bill initially levied by the Revenue Commissioners on pharmaceutical firm Perrigo.

The company confirmed last September that it had settled the largest ever tax bill levied by the Revenue Commissioners for €297 million.

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The disputed tax bill related to the sale by Irish pharma company Elan of its intellectual property interests in multiple sclerosis drug Tysabri in 2013 to Biogen for an up-front payment of $3.25 billion and a share of future royalties. That sale took place months before Perrigo bought what was left of Elan.

In her statement accompanying the annual report, TAC chairperson, Marie-Claire Maney stated that the TAC last year issued appeal determinations to a value of €443 million – this compares to a quantum of €610 million in 2020.

The bulk of determinations last year concerned corporation tax of €405 million.

Ms Maney said that the TAC “further reduced our appeals on hand by a further 10 per cent to 2,703”.

She went on to say that the headline statistics in the report “demonstrate the significant progress made” in 2021.

A breakdown of the €3.14 billion in appeals closed last year show that  largest proportion concerned corporation tax of €2.9 billion or 92 per cent of the overall total.

Last year, the TAC scheduled 188 hearings affecting 309 appeals with a total quantum of €1.962 million over 333 days.

The €3.14 billion total in appeals closed out also included €1 million in Covid-19 related tax appeals concerning employment wage subsidy schemes and Covid Restrictions Support Scheme (CRSS).

The figures show that 860 income tax cases with a value of €135.8 million were settled with capital gains tax accounting for the third highest amount at €46 million.

In 2020, a Protected Disclosure was made to the Minister for Finance in respect of the commission and the 2021 annual report said that the commission fully cooperated with this investigation which concluded in 2021 with no allegation of wrongdoing being upheld in whole or in part and the matter is now resolved.