Tax Appeals Commission determination 37TACD2023 regarding PRSI, PAYE, 2023

Administrative Decision Number37TACD2023
Date22 December 2022
Subject MatterPRSI, PAYE
RespondentThe Revenue Commissioners
The Revenue Commissioners
1. This is an appeal to the Tax Appeals Commission (“the Commission”) pursuant to and in
accordance with the provisions of section 949I of the Taxes Consolidation Act 1997 (“the
TCA 1997”) brought on behalf of (“the Appellant”) against Notices of
Estimation of Amounts Due issued by the Revenue Commissioners (“the Respondent”) on
16 February 2021, in respect of the years of assessment 2016 and 2017. The total
liabilities reflected in the Notices of Estimation of Amounts Due in respect of
PAYE/PRSI/USC is in the sum of €36,873.72.
2. The liabilities arose as the Respondent disallowed deductions on the basis that such
deductions were not incurred by the Directors of the Appellant travelling in the
performance of the duties of that office or employment, or otherwise to expend money
wholly, exclusively and necessarily in the performance of those dutiesin accordance with
section 114 TCA 1997.
3. On the 12 April 2021, the Appellant duly appealed to the Commission. The appeal
proceeded by way of a remote hearing on 25 November 2022. The Appellant was
represented by , Head of Accounts for the Appellant (“the Appellant’s

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