Full coverage: Tax Appeals Commission

Yesterday, we revealed how the High Court had ruled against a major offshore tax scheme. Today, tax barrister and chartered accountant Eoin O’Shea picks through the detail of the judgement and analyses each of the questions that the court sought to answer.

For more than a decade, the Irish tax authority has sought to curb a complex tax scheme used by 231 high earners. The High Court has now ruled in Revenue's favour, and the judgement sheds new light on how the scheme operated.

Through a series of mergers and demergers in the last decade, a global pharmaceutical manufacturer became Irish. To defend itself against a Vat claim, it had to reveal the details of the scheme.

Are final payments described as “success fees” and “bonuses” taxable as annual income or eligible to lump sum relief? A four-year battle has just come to an end.

Exchequer returns showed swings of hundreds of millions of euros between 2020 and 2021 following a dispute on emergency stamp duty rules. The exact details of the settlement reached between AbbVie and the tax authority, however, remain secret.

Described by Revenue as a “blatant misuse or abuse” of the tax code, a leveraged bond scheme gave rise to an inflated CGT loss of €34.6m for a husband and wife. But just how did it work? And why is the Revenue struggling to stop it?

When the Irish treasury subsidiary of an overseas manufacturing group gained €200 million thanks to a loan waiver, the company declared this as non-taxable income. This led to a major test case.

For the past decade, the Revenue Commissioners have pursued the Co Kerry horseracing organisation for corporation tax, arguing that betting and other ancillary activities were not sport. The case has now made its way through the High Court.

To the relief of thousands of counsellors, psychotherapists and chiropractors, the authorities have said Vat need not be charged on their fees. However a practitioner of Chinese medicine and acupuncturist was not so lucky.

On the basis of his word alone, a property investor tried to convince Revenue he was entitled to €750,000 in loss relief arising from a string of major property deals. It didn't go well.