Revenue Note for Guidance

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Revenue Note for Guidance

CHAPTER 3

Pre-hearing proceedings

949Q Statement of case

Summary

Certain information may be required to be provided by the parties to facilitate the adjudication of a matter under appeal. This information is referred to as a ‘statement of case’ and includes the relevant statutory provisions, the relevant case law and an outline of the relevant facts as well as any other information as the Appeal Commissioners consider necessary to enable them to schedule a hearing.

The Appeal Commissioners may request information via the ‘statement of case’ to learn whether there is scope for settling the matter by agreement with Revenue, whether the matter could be determined without holding a hearing or whether a public or a private hearing is sought.

Details

(1) The Appeal Commissioners may direct that a party provide specified information (referred to as a “statement of case”) after an appeal is accepted.

(2) Information gathered by way of case stated assists the Appeal Commissioners in deciding on the appropriate way to conduct the proceedings. Among other things, a party may be directed to provide:

  • the relevant statutory provisions,
  • the relevant case law,
  • an outline of the relevant facts,
  • an estimation of the likely duration of a hearing
  • whether there is scope for settling the matter by agreement with Revenue,
  • whether the matter could be determined without holding a hearing,
  • whether a public or a private hearing is sought, and
  • any other information as the Appeal Commissioners consider necessary to enable them to schedule a hearing.

Relevant Date: Finance Act 2021