Tax Appeals Commission determination 125TACD2022 regarding Relevant Contracts Tax, 2022

• Administrative Decision Number: 125TACD2022
• Year: 2022
• Date: 19 July 2022
• Subject Matter: Relevant Contracts Tax
• Respondent: THE REVENUE COMMISSIONERS

1

125TACD2022

Between:

Appellant

and

THE REVENUE COMMISSIONERS

Respondent

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Determination

_________________________________________________

Introduction

1. This matter comes before the Tax Appeal Commission (hereinafter "the Commission") as

an appeal against the refusal of the Revenue Commissioners (hereinafter "the

Respondent") of a claim for the repayment of tax pursuant to section 865 of the Taxes

Consolidation Act, 1997 (hereinafter the "TCA1997") made by the Appellant in respect of

the tax year 2015.

2. The amount of tax at issue is €4,790.00.

Background

3. Mr (hereinafter the “Appellant”) is a UK resident individual who was

engaged in construction work in the State. The Appellant was subject to Relevant Contacts

Tax (hereinafter “RCT”) pursuant to section 531 of the TCA1997 in 2015. Sub-contractors

who are deemed not to have a Permanent Establishment in the State can apply for refunds

of RCT by completing a Tax Repayment Claim Form IC1 and returning it to the

Respondent.