Taxes Consolidation Act 1997 section 949P

Effect of enforcement action for collection of tax

Section 949P restricts the Appeal Commissioners from accepting a late appeal where tax enforcement action is in progress, and prevents the appellant from recovering enforcement costs even if a late appeal is subsequently admitted.

• The Appeal Commissioners cannot accept a late appeal while court proceedings or sheriff enforcement action to recover the disputed tax remain ongoing.
• A late appeal may only be considered once the enforcement action has been fully completed.
• If a late appeal is accepted after enforcement has concluded, the appellant cannot recover any costs already paid in connection with that enforcement.
• Irrecoverable costs include legal costs of court proceedings and any fees or expenses charged by the county registrar or sheriff.