The Tax Appeals Commission (TAC) has received 15 tax appeals with an estimated value of €417 million in the first two weeks of 2025 – more than double the entire estimated value of €207 million in appeals received in 2024.
Figures published in the 2024 TAC annual report show that the estimated €417 million in appeals is also €34 million more than the entire €383 million quantum in appeals that the TAC had on it books at the end of 2024. This includes appeals carried over from previous years.
The surge in appeals during the first two weeks of the year has resulted in the commission revising its 2025 targets estimating now that there will be a €750 million quantum in appeals on hand at the end of this year.
The figures show that the largest proportion of new appeals last year concerned disputed corporation tax with an estimated value of €94 million.
The €383 million quantum in appeals on hand at the end of 2024 is down sharply from the €1.7 billion on hand at the end of 2021.
The figures show that last year, the TAC closed out appeals valued at €355 million.
In a breakdown of the €355 million figure, cases valued at €193 million were settled; €122 million in appeals were withdrawn by appellants; the TAC issued 180 determinations with a value of €34 million while the remaining appeals with a value of €6 million were refused, dismissed or merged with other appeals.
Appeals with a value of €193 million concerned corporation tax.
During 2024, 280 hearings affecting 507 appeals with a total value of €390 million were scheduled over 456 days. The duration of the hearings ranged from a half day to three weeks.
In her report, chairperson, Marie-Claire Maney said that “for the sixth year running the commission closed more appeals than it received, reducing the number of appeals on hand from 1,141 to 711, notably a 38 per cent decrease”.
She said: “This marks the lowest number of appeals on hand since the establishment of the commission. The appeals determined and closed have released back to the exchequer or the economy €355 million in 2024.”
“The increasing complexity of the legal issues in appeals is a continued trend in 2024, with the impact of European Treaties and Directives to the fore,” she added.
During 2024 the TAC signed 11 cases to be appealed to the High Court. Of those eight were requested by appellants and three by the Revenue Commissioners
