It was, by any standard, an important judgment. For more than a decade, the Irish tax authority had sought to curb a complex tax scheme used by 231 high earners in 2009 and 2010. And in July, the High Court ruled in Revenue’s favour. The judgment sheds new light on how the scheme operated. But crucially, as Eoin O’Shea detailed at the time, it also set new ground in tax law, stating that if there was any “ambiguity” in the tax code, it must be interpreted in the “taxpayer’s favour”. While it did not do the individuals involved in the…

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