Review of Revenue Opinions or Confirmations

---

The Revenue Commissioners are reminding taxpayers that opinions/confirmations issued by Revenue in the period between 1 January and 31 December 2013 are subject to review. A taxpayer who wishes to continue to rely on any opinion / confirmation issued by Revenue in the period between 1 January and 31 December 2013 (and which has not already ceased to have effect before 1 January 2019) as respect any transaction, or the whole or part of any period, after 1 January 2019, is required to do the following by 29 March 2019:

• Supply evidence of the opinion/confirmation, being a copy of a written communication which originated from Revenue, and
• Lodge a full application for the renewal or extension of the opinion/confirmation with the Revenue District dealing with the taxpayer’s affairs. The application must be in full compliance with Revenue procedures in relation to obtaining an opinion/confirmation from Revenue, as contained in Tax and Duty Manuals Part 37-00-40 and Part 37-00-00a.

All opinion/confirmations issued by Revenue between 1 January and 31 December 2013, and which had not already ceased to have effect, cannot be relied on by any taxpayer or tax practitioner in respect of any transaction, period or part of a period, after 1 January 2019 where an application for its renewal or extension is not made in accordance with the above steps.

If you would like to discuss this topic further, please contact your OSK Tax Adviser on 01-439 4200 or email advice@osk.ie

Share this Post