Revenue Commissioners -v- Droog [2011] IEHC 142 (High Court, Laffoy J, 31 March 2011)
High Court decides, by way of case stated, that the Appeal Commissioner was correct in determining that the four-year time limits provided in sections 955 and 956 of the Taxes Consolidation Act 1997 applied to the forming of an opinion in relation to tax avoidance schemes under section 811 of the Act.
Taxation - decision of Appeal Commissioner - case stated - s 941, Taxes Consolidation Act 1997 - loss arising from partnership - whether a tax avoidance scheme - whether notice of opinion by Revenue Commissioners out of time by virtue of sections 955 and 956 of 1997 Act - invocation of anti-avoidance measures nine years after self-assessment - section 811, 1997 Act - whether term "at any time" in section 811 had effect of disapplying time bars in sections 955 and 956 of 1997 Act.Full Text on Court Services Website>
Key Cases Cited
-
D.B. v. Minister for Health [2003] 3 I.R. 12
Cronin (Inspector of Taxes) v. Cork and County Property Company Ltd. [1986] I.R. 559
Harris v. Quigley[2006] 1 I.R. 165
Keogh v. Criminal Assets Bureau [2004] 2 I.R. 159
Cape Brandy Syndicate v. Inland Revenue Commissioners [1921] 1 KB 64
You must log in to post a comment.