knowledge 20 April 2017 |

Irish Revenue issue eBrief on updates to their Opinion and Confirmations Manual

The eBrief confirms how a taxpayer should contact Large Cases Division to request an opinion/confirmation. In the case of a taxpayer who is participating in the Cooperative Compliance Framework, directly in writing to the dedicated Case Manager assigned to that taxpayer. In the case of a taxpayer who is not participating in the Cooperative Compliance Framework, to largecasesdiv@revenue.ie using My Enquiries via ROS. This change is in keeping with the stated purpose of the Cooperative Compliance Framework where Revenue have indicated that those taxpayers who are not participating in the Cooperative Compliance Framework will lose direct access to their dedicated Case Managers.

The eBrief also includes details of the additional mandatory information that must be supplied at the time of making a request for an opinion/confirmation where EU and/or OECD exchange of information requirements apply, including the following:

• Where the taxpayer is not resident in the State, their country of tax residence;
• Name of group to which taxpayer belongs, if applicable;
• Name and country of residence of any other party or parties involved in the transaction or situation;
• Details of any information included in the request that should not be disclosed due to the fact that it would lead to the disclosure of a commercial, industrial or professional secret or of a commercial process.

To the extent that you require further information regarding the content of this eBrief please feel free to contact a member of our Tax Department.

You may access the eBrief here.