Tax Appeals Commission determination 24TACD2023 regarding PREM, 2023

Administrative Decision Number24TACD2023
Date12 December 2022
Subject MatterPREM
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 July 2019 and 23 July 2019, in respect of the years of
assessment 2016, 2017 and 2018. The total liabilities reflected in the Notices of Estimation
in respect of PAYE/PRSI is in the sum of €14,807.35.
2. The liabilities arose in circumstances where the Respondent disallowed deductions on the
basis that such deductions were not wholly and exclusively laid out or expended for the
purposes of the trade or profession’ in accordance with section 81(2) TCA 1997.
3. On the 30 July 2019, the Appellant duly appealed to the Commission. The appeal
proceeded by way of a remote hearing on 22 November 2022 and the Commissioner heard
evidence from and and submissions on behalf of the Respondent.

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