InDisputes: Irish Tax Appeals Lookback To 2025 And Possible Change Signalled

The recently published annual report of the Tax Appeals Commission (“TAC”) provided a valuable insight into what happened at this forum in 2025. We examine some of the detail in that report below, highlight some of our learnings from appearing before TAC and flag some changes to the Irish tax appeals process that are currently under consideration.

TAC Annual Report

TAC’s annual report for 2025 shows that it continues to be an effective and efficient forum for the resolution of tax appeals. For the seventh year in a row, the TAC closed more appeals than it received resulting in the TAC carrying about six months of cases in progress which, as the report notes, is a remarkable figure for any decision-making body.

The annual report also notes “[t]he increasing complexity of the appeals over multiple tax heads and referencing European law continued to be a trend in 2025”, which is consistent with our experience in practice.

The key statistics for 2025 are as follows:

Appeals closed

• The TAC closed 1,286 appeals, valued at €605 million, representing a 13% fall in the number of appeals in progress from 2024.
• Of the 1,286 appeals closed, 464 were resolved by settlement, representing €423 million – the largest quantum category of closures.
• Corporation tax appeals were significantly the highest value appeals closed, with 68 appeals closed valued at €423 million.

Appeals received

• The TAC received 1,192 appeals, valued at €765 million. This is almost a fourfold increase in value from 2024, when 1,281 appeals valued at €207 million were received.
• 56 appeals received related to corporation tax, valued at €492 million, representing 64% of the quantum of tax in appeals received.

Hearings & determinations

• 237 hearings were scheduled valued at €495 million. 96 hearings were scheduled remotely representing a 62% increase in remote hearings from 2024.
• 216 determinations were issued valued at €32 million, a 20% increase on the number issued in 2024.

Taxpayer readiness

The TAC’s efficient case management process frequently results in hearings being scheduled and heard within a year. Given this swift timeline and the increasing complexity of tax law issues, it is critical that taxpayers start preparations for any potential dispute as early as possible. Key issues to consider from the outset include (i) the legal basis and grounds of appeal, which often involve areas of law beyond the tax legislation and may necessitate consideration of other forums such as the European Courts or the Irish Court system, and (ii) the evidentiary burden which will have to be discharged. In our experience, taxpayers who fail to properly prepare their case from an early stage on either front can encounter difficulties at later stages in proceedings.

Looking ahead – Finance (Tax appeals and fiscal responsibility) Bill 2024

Another key watchpoint in this area is the progress of the Finance (Tax Appeals and Fiscal Responsibility) Bill 2024 (the “Bill”) which proposes changes to the tax appeal process. As it stands, taxpayers have an automatic right to have their tax appeals heard in private. Under the current proposal, the Bill will default to public hearings of tax appeals with discretion for TAC to hear certain appeals in private.

On 8 May 2026, the Joint Oireachtas Committee on Finance, Public Expenditure, Public Services Reform, Digitalisation and Taoiseach (the “Committee“) published its report following pre-legislative scrutiny of the Bill. The Committee’s primary recommendation is that no changes should be made to the existing procedures for private and public hearings at the TAC. The Committee also recommended that the Minister should assess whether the proposed changes would render Ireland’s tax system more punitive compared to European peers, with potential adverse consequences for foreign direct investment.

Matheson will continue to monitor developments closely.

Key takeaways for taxpayers from the report

• The annual report signals an increasingly high-value appeals environment, reinforcing the need for taxpayers to be dispute-ready from the outset of any Revenue intervention.
• Although corporation tax accounted for only 5% of appeals received in 2025, it represented 64% of the quantum of tax in dispute. The high value nature of corporation tax disputes means taxpayers are operating in a high-scrutiny environment where early and comprehensive preparation, including in relation to contemporaneous documentation and evidence, is particularly important.
• The growing complexity of appeals, including multi-tax-head disputes and European law considerations, reinforces the importance of early and comprehensive legal advice. Taxpayers should assess at the outset whether the appeal raises issues of European law or requires consideration of other appeal forums (such as, for example, judicial review).
• The TAC’s efficient case management means taxpayers should prepare for appeals promptly and thoroughly from the outset.
• Taxpayers should monitor the progress of the Bill as it could result in far-reaching changes to the current Irish tax appeals system.

Contact us

Should you have any questions or wish to discuss any aspect of TAC’s Annual Report on Irish tax appeals in more detail, please speak to any of our Tax partners or to your usual Matheson contact.