Ireland: Tax Authorities

The Supreme Court of Ireland has issued a landmark ruling on litigation funding arrangements, examining whether conditional fee uplift agreements and "no foal, no fee" structures violate champerty laws. This decision arose from a tax debt recovery case where taxpayers challenged the Revenue Commissioners' fee arrangements with their legal panel, arguing these agreements were unenforceable under Irish law.

The Tax Appeals Commission's 2025 annual report reveals significant trends in Irish tax dispute resolution, including a fourfold increase in appeal values and growing complexity of cases involving European law. With corporation tax disputes representing 64% of the quantum despite only 5% of appeals, and proposed legislative changes potentially shifting to public hearings, taxpayers face an evolving landscape requiring early preparation and strategic readiness.

The Court of Justice of the European Union has ruled on whether intra-group transfer pricing adjustments constitute consideration for separate supplies of services subject to VAT. While the judgment provides clarity on routine profit margin adjustments, it raises questions about the broader treatment of year-end transfer pricing adjustments and their VAT implications for multinational enterprises.

Ireland has introduced Section 1009A of the Taxes Consolidation Act 1997, marking the first time Irish legislation directly addresses the tax transparency of foreign entities. This groundbreaking provision has significant implications for cross-border investment structures involving Irish funds, particularly those utilizing Delaware limited partnerships, U.K. LLPs, and U.S. LLCs, with downstream consequences for Pillar 2 and anti-hybrid mismatch rules.

Last week, the EU announced that it has reached political agreement on the reform of the EU Customs Union, representing the most significant overhaul of the EU customs legal framework since the establishment of the Customs Union in 1968. It was also announced that Lille (France) will host the new EU Customs Authority.

Against a backdrop of sustained political pressure to address Europe’s innovation and competitiveness gap, the European Commission has published its long-anticipated legislative proposal for an EU-wide corporate legal form, commonly referred to as “EU Inc”. The proposal forms the centrepiece of a new “28th regime” corporate legal framework, introducing a harmonised EU-wide company form aimed primarily at supporting startups and scaleups, while being open to all founders and companies across the Union.

The Irish Department of Finance published a comprehensive review on the taxation of interest in Ireland in September 2024.

On 30 September 2025, the European Commission (the Commission) published its recommendation on Increasing the Availability of Savings and Investment Accounts...

Revenue have published a new Tax and Duty ManualOpens in new window which provides details of an opportunity granted to employers to correct payroll tax issues...