Yesterday, 26th January 2017, the Irish Revenue issued an eBrief confirming that all opinions / confirmations issued by them have a maximum validity of 5 years, or shorter period as may be specified by Revenue when providing the opinion / confirmation.

Where a taxpayer is relying on an opinion / confirmation provided by Revenue, they should check the date that the opinion was issued. If the taxpayer wishes to continue to rely on an opinion issued before 1 January 2012 for any transaction, or the whole or part of any period, after 1 January 2017, they will need to take the following steps by 30 June 2017:

  • Supply Revenue with a copy of the written opinion / confirmation previously received from Revenue, and
  • Submit a full application for the renewal or extension of the opinion / confirmation to the relevant Tax District that deals with their affairs.

Furthermore, renewal and extension applications must comply with the requirements of Revenue’s Tax and Duty Manual 37.00.40 and the Revenue Technical Service (RTS) Guidelines.

If you have any queries regarding the impact of this eBrief please feel free to contact us

To access the eBrief, please click here