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.

Relevant Experience

• 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