In response to the Deputy’s question the following tables provide an outline of the number of appeals received and closed from 2016 to the end of June 2021 and the reason why each appeal was closed:
Appeals Received and Closed from 2016 to June 2021
Year
|
No. of Appeals Received
|
No. of Appeals Closed
|
2016
|
2,357
|
206
|
2017
|
1,747
|
689
|
2018
|
1,689
|
1,439
|
2019
|
1,494
|
1,579
|
2020
|
1,039
|
1,392
|
2021 (to end-June)
|
747
|
862
|
Total
|
9,073
|
6,167
|
Reason for Closures, 2016 to June 2021
How Closed
|
2016
|
2017
|
2018
|
2019
|
2020
|
2021*
|
Total
|
Determinations Issued
|
14
|
37
|
45
|
119
|
191
|
97
|
503
|
Dismissed
|
1
|
41
|
162
|
95
|
16
|
89
|
404
|
Merged / Consolidated
|
1
|
17
|
17
|
4
|
6
|
1
|
46
|
Refused
|
55
|
7
|
325
|
180
|
63
|
87
|
717
|
Settled
|
96
|
410
|
667
|
729
|
509
|
293
|
2,704
|
Withdrawn by Appellant
|
39
|
177
|
223
|
452
|
607
|
295
|
1,793
|
Total
|
206
|
689
|
1,439
|
1,579
|
1,392
|
862
|
6,167
|
*2021 figures are to end June 2021 only.
While an appeal is being progressed by the Commission, at any time before a determination is issued, the Revenue Commissioners and Appellants are entitled to negotiate with each other to reach a settlement. This can occur for a number of reasons and the Commission is not a party to those negotiations or the reason for the settlement.
As an appeal is progressed, settlements can take place when additional information, sought by the Commission in advance of a determination being issued, is revealed to both parties giving a clearer understanding of how the tax dispute was arrived at. On other occasions, the additional requirements by the Commission to progress the appeal prompt parties to begin negotiations. Settlements can be a favourable outcome for the parties saving time and legal costs. The Commission can also close the appeal without the need to hear the appeal and draft a determination.
Once a determination is used by the Commission, the parties can then only appeal to the High Court on a point of law.