Did you know that Revenue opinions/ confirmations have a maximum life of five years?

Tax legislation can be open to interpretation. Therefore, in particularly unusual and complex transactions, taxpayers can obtain written opinions/confirmations from Revenue in an effort to clarify matters. In January 2017 the Revenue issued eBrief 08/2017 confirming the current Revenue view that any opinions/confirmations issued have a maximum life of five years, assuming all facts and circumstances detailed in the original request remain unchanged. The eBrief further advises that a taxpayer who wishes to continue to rely on an opinion issued before 1 January 2012 must:


by 30 June 2017. If a taxpayer does not apply for an extension all opinions issued prior to 1 January 2012 will cease to have effect from 1 January 2017.

If the 30 June 2017 deadline passes without the opinion/confirmation being renewed a new Revenue Opinion / Confirmation should be obtained from the appropriate Revenue area dealing with a taxpayer’s affairs - either the local Revenue District or Large Cases Division. In their guidance notes the Revenue advise the following –

Any opinion/confirmation in relation to a proposed transaction or business activity is appropriate only where the circumstances are complex, or unusual, or information is not readily available, or there is genuine uncertainty in relation to the interpretation or application of the relevant tax/duty rules.

Further details on how to apply for an opinion are contained in the Revenue Tax and Duty Manual at Part 37-00-40 and Part 37-00-00a.

Please contact Róisín McDaid in OSK Tax if you wish to have an existing opinion/confirmation renewed or if you wish to apply for a new opinion/confirmation.


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