I propose to take Questions Nos. 130 and 156 together.
I am advised by the Revenue Commissioners that the High Court decision concerning the deductibility against rental profits of the Non Principal Private residence charge (NPPR) has been appealed by them to the Court of Appeal. While that appeal is pending Revenue is not in a position to amend assessments or process repayment claims based on the High Court judgement.
Revenue further advises that there is a general right to repayment of tax provided for in Section 865 of the Taxes Consolidation Act 1997, where a person has paid an amount of tax which is not due. However that right is subject to a statutory limit of four years from the end of the chargeable period to which the claim relates. That statutory limit is binding on Revenue. Any repayment claims made in relation to this matter that are received within the statutory time limits, as they apply to each year of assessment, will be retained and processed when the outcome of the Appeal case is known.