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

• Administrative Decision Number: 37TACD2023
• Year: 2023
• Date: 22 December 2022
• Subject Matter: PRSI, PAYE
• Respondent: The Revenue Commissioners

1

Between

Appellant

and

The Revenue Commissioners

Respondent

Determination

Introduction

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 duties” in 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

37TACD2023