Tax Appeals Commission determination 24TACD2023 regarding PREM, 2023

• Administrative Decision Number: 24TACD2023
• Date: 12 December 2022
• Subject Matter: PREM
• 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 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.

24TACD2023