Taxes Consolidation Act 1997 section 959AJ

Appeals against time limits for making enquiries and taking actions

Section 959AJ provides a right of appeal to the Appeal Commissioners where a chargeable person believes that a Revenue enquiry or action has been commenced outside the permitted four-year time limit.

• A chargeable person who believes Revenue has commenced an enquiry or action after the four-year limit has expired may appeal to the Appeal Commissioners within 30 days of the enquiry or action beginning.
• Where an assessment has already been made or amended on foot of such an enquiry, the chargeable person may instead appeal against that assessment under the normal assessment appeal provisions.
• Once an appeal is made, any obligation on the chargeable person arising from the enquiry is suspended and Revenue must take no further action until the Appeal Commissioners have made their determination.
• If the Appeal Commissioners find that Revenue was precluded from making the enquiry, the chargeable person is released from any obligation and the officer is prohibited from pursuing the matter; if Revenue was not precluded, the officer may continue.