I have a client who incorrectly declared income from a foreign jurisdiction in his Irish tax return. The income has been assessed in the foreign jurisdiction. Revenue are of the opinion that the payment made to Irish Revenue based on the incorrectly declared income is now statute barred and they will not refund the tax to my client to enable him to settle the tax arising in the foreign jurisdiction. This is not a credit or relief but actual tax incorrectly paid over to revenue. Can the four year time bar apply in this situation? My client is considering an appeal.
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