Taxes Consolidation Act 1997 section 949AT

Revenue Commissioners to give effect to decisions of High Court, Court of Appeal and Supreme Court

Section 949AT requires Revenue to give effect to Appeal Commissioners' determinations that have been reversed, affirmed or amended by the Higher Courts, but suspends that obligation while any further appeal remains undecided.

• Revenue must give effect to an Appeal Commissioners' determination that has been reversed, affirmed or amended by the High Court or the Court of Appeal, in the same way as it would to a determination that has not been through the courts.
• Where a High Court decision is appealed to the Court of Appeal, Revenue's obligation to give effect to the determination is suspended for the duration of that appeal.
• Where the Supreme Court agrees to exercise its appellate jurisdiction over a High Court or Court of Appeal decision, the same suspension applies while the Supreme Court appeal remains undisposed of.
• The effect is that Revenue is never required to act on a determination while there is still a live appeal before a higher court.