Tax Appeals Commission determination 107TACD2023 regarding Income Tax, 2023

• Administrative Decision Number: 107TACD2023
• Date: 06 June 2023
• Subject Matter: Income Tax
• Respondent: THE REVENUE COMMISSIONERS

1

107TACD2023

Between:

Appellant

and

THE REVENUE COMMISSIONERS

Respondent

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Determination

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Introduction

1. This appeal comes before the Tax Appeals Commission (hereinafter the “Commission”)

against a decision of the Revenue Commissioners (hereinafter the “Respondent”) on 16

December 2022 to refuse relief to the Appellant under the Special Assignee Relief

Programme (hereinafter “SARP”) provided for under section 825C of the Taxes

Consolidation Act 1997 (hereinafter the “TCA1997”).

Background

2. Mr (hereinafter the “Appellant”) moved to Ireland from the United Kingdom

on 14 February 2022 to take up employment by way of a transfer within his existing

employers structure.

3. On 18 October 2022 the Appellant’s employer in Ireland completed and submitted a Form

SARP 1A to the Respondent. The Form SARP 1A is entitled “Certification by employer

under Section 825C of the Taxes Consolidation Act 1997. Relief under the Special

Assignee Relief Programme (SARP)”.