Our Tax Disputes team is made up of members of our market-leading Litigation, Dispute Resolution and Investigations group and our Tax groups. We advise on all aspects of national and international tax disputes and combine in-depth technical analysis of tax issues with strategic litigation advice.
The team works on an integrated basis with the other groups in the firm and advises on all tax disputes matters. The combination of litigators and tax lawyers is a highly effective means of conducting a tax dispute, as it combines an in-depth technical and policy-based analysis of the relevant tax issues by leading tax lawyers with the appreciation of strategy, tactics and process that are second nature to a litigator.
We have successfully represented clients before the Tax Appeal Commission (“TAC”), the High Court, Court of Appeal and Supreme Court.
In addition we advise a range of clients including multinationals on Revenue investigations and on ancillary enforcement issues in respect of Mutual Legal Assistance Treaties (“MLATs”) requests and orders.
- Advising a number of parties on German tax authorities investigations into Cum-Ex trading
- Acting for Dunnes Stores in judicial review proceedings before the High Court and Supreme Court seeking to quash assessments issued by the Revenue Commissioners for the recovery of over €36.5 million from Dunnes Stores for the plastic bag levy. Among other things, the proceedings challenged the validity of the regulations that introduced the plastic bag levy – the Waste Management (Environmental Levy) (Plastic Bag) Regulations 2001 – and, in particular, their applicability to plastic bags not used at the point of sale
- Acting for a large multinational in a very significant dawn raid by the Revenue Commissioners, enforcing an MLAT request under the Criminal Justice (Mutual Assistance) Act 2008, the first of its kind into a plc in Ireland
- Acting for Canada Life (subsidiary of Great West Lifeco Inc.) in relation to a tax dispute with the Revenue Commissioners arising from Canada Life’s €1.3 billion purchase of Irish Life from the Minister for Finance. We succeeded before the TAC and on appeal to the High Court
- Acting in successful judicial review proceedings in the Court of Appeal for the Stanley family arising from a dispute concerning the limitation time period within which the Revenue Commissioners may lawfully raise an assessment to tax
- Acting for a large multinational before the TAC in relation to the tax and corporate law classification of payments for share-based compensation
- Acting for a prominent tech company in wide-reaching Revenue proceedings with multi-jurisdictional implications for the client. In addition to domestic tax law, the proceedings also consider the implications of the Mutual Assistance Directive and provisions of data protection law
- Acting for a holding company before the TAC in relation to a significant dispute on VAT recovery
- Acting for a large Plc before the TAC in a dispute relating to the cross-border taxation of its CEO’s compensation package