Tax Appeals Commission determination 146TACD2023 regarding Income Tax, 2023

• Administrative Decision Number: 146TACD2023
• Date: 08 September 2023
• Subject Matter: Income Tax
• Respondent: REVENUE COMMISSIONERS

1

Between

Appellant

and

REVENUE COMMISSIONERS

Respondent

Determination

Introduction

1. This is an appeal to the Tax Appeals Commission (“the Commission”) by

(“the Appellant”) against an amended notice of assessment to income tax dated 27

November 2019 raised by the Revenue Commissioners (“the Respondent”), in respect of

the tax year ending 31 December 2016, in the amount of €429,996.90. The assessment

arose on foot of the exercise by the Appellant of employee share options.

2. The appeal proceeded by way of a hearing on 4 September 2023.

Background

3. The Appellant is a citizen of the In 2016 he was employed by

an Irish-registered company, and stated that he was seconded to a based company.

He submitted his Form 11 income tax return for 2016 on 16 November 2017. The return

stated that his income for 2016 was €271,384. The return did not state that the Appellant

was non-resident in the State.

146TACD2023