RDJ Senior Associate Mark Ludlow is a regular contributor to the Irish Tax Review, writing the feature Direct Tax Cases: Decisions from the Irish Courts and Tax Appeals Commission Determinations. The current feature examines decisions which considered:
- the jurisdiction of the Appeal Commissioners;
- whether a settlement agreement with Revenue can preclude a prosecution;
- whether and in what circumstances Revenue must disclose information to a taxpayer in the course of an appeal;
- the meaning of ‘interest in land’;
- the meaning of ‘proprietary director’; and
- whether the loan element of a ‘stapled investment’ was a ‘debt on security’.
Read the full article here.
This article first appeared in Irish Tax Review Issue 3 (2023) © Irish Tax Institute.