Our Tax Disputes team provides expert Irish legal advice on a wide range of tax investigations and tax disputes with the Irish Revenue Commissioners and overseas tax authorities. The team also advise clients on matters relating to tax disputes or potential tax disputes, such as cases involving contractual or indemnity claims with third parties relating to tax liabilities as well as on matters involving assessment and protection against tax risk.
The Maples Group has a market leading Tax Disputes practice. Andrew Quinn, William Fogarty and Jean-Dominique Morelli from our Tax team and Robin McDonnell, Kevin Harnett and Eugene McCormick from our Litigation team lead this practice and together form an integrated and technical team of experts with the combined expertise to deal with all aspects of a tax dispute.
We regularly represent and advise on a wide range of tax investigations and disputes with the Irish Revenue Commissioners, Luxembourg tax authorities and overseas tax authorities. We also advise clients on matters relating to tax disputes or potential disputes, such as cases where there are contractual or indemnity claims with third parties relating to tax liabilities and also matters involving assessing and protecting against tax risk.
In our experience, tax authorities worldwide have become more assertive in investigating and disputing the affairs of taxpayers. In Ireland, there have been a number of high profile Irish Revenue interventions in recent times. For example, in 2018, the Irish Revenue Commissioners issued a tax assessment for €1.64 billion on an Irish subsidiary of Perrigo Company plc, an international US listed healthcare group, and in 2019 an assessment against Takeda, the pharmaceutical company, for €398 million. In Luxembourg, there has also been a notable increase of tax disputes.
Many Irish and Luxembourg tax disputes do not result in public litigation. Although some of our work is public, such as our representation in the courts, for financial institutions a large amount of our work is undertaken privately and without disclosure. We have considerable expertise in assisting with enquiries, audits and the negotiation of settlements with tax authorities. The creation of the Irish Tax Appeals Commission in 2016, which replaced the Appeal Commissioners regime, has created a more formalised and rigorous process for appeals from assessments by the Irish Revenue Commissioners. Where settlements with the tax authorities cannot be achieved, we work closely with our clients to assist them in the robust pursuit of appeals against erroneous assessments.
