Tax

Taxation is one of the most complex areas of Irish law, and when disputes arise, they can expose businesses and individuals to significant financial and reputational risks. Revenue audits, investigations, and assessments often escalate into contentious disputes involving detailed statutory interpretation, technical financial evidence, and litigation before the Tax Appeals Commission or the Irish courts.

At Fenecas Law LLP, we specialise in acting for corporates, financial institutions, executives, and private clients when contentious tax issues arise. We understand the high stakes involved: preserving value, protecting reputation, and ensuring compliance with the law, all while engaging with Revenue in a constructive but robust manner.

Types of Contentious Tax Disputes We Handle

Our contentious tax practice covers a broad range of disputes, including:

Revenue audits and investigations – Advising businesses and individuals under Revenue scrutiny, including dawn raids and information demands.
Assessments and liabilities – Challenging disputed assessments for corporation tax, VAT, PAYE, CGT, stamp duty, and other liabilities.
Transfer pricing disputes – Contentious claims involving cross border pricing arrangements, permanent establishment issues, and OECD compliance.
Tax avoidance and anti avoidance disputes – Acting in challenges based on general anti avoidance rules (GAAR) and specific anti avoidance provisions.
Indirect tax disputes – Contentious issues around VAT recovery, customs duties, and excise.
Employment tax disputes – PAYE audits, classification of contractors vs employees, and PRSI contribution disputes.
Capital gains and stamp duty litigation – Complex disputes arising from share sales, property transactions, and corporate restructurings.
Tax penalties and criminal investigations – High stakes defence in cases involving allegations of fraud, wilful default, or deliberate tax evasion.
Double taxation and cross border matters – Disputes involving international taxation, treaty interpretation, and relief under EU law.

Each dispute has its own legal and commercial pressures, requiring both technical expertise and strong contentious instincts.

Tax Appeals & Court Representation

Most substantive tax disputes in Ireland are addressed through the Tax Appeals Commission (TAC). We act for corporates, financial institutions, and individuals in:

Preparing detailed appeals of Revenue assessments.
Managing expert evidence, including accountancy and valuation input.
Representing clients at TAC hearings.
Appealing TAC determinations to the High Court and beyond.

Where issues escalate further, we act in complex litigation before the High Court, Commercial Court, Court of Appeal, and Supreme Court, ensuring that all aspects of the case—from statutory interpretation to evidential process—are meticulously argued.

Acting for Corporates & Institutions

For corporate and institutional clients, tax disputes often involve very significant sums, reputational exposure, and parallel regulatory considerations. We assist in:

Defending high value corporation tax and VAT assessments.
Transfer pricing disputes involving multinational operations.
Employment tax disputes in the technology, construction, and financial services sectors.
Appeals regarding complex restructuring, merger, or acquisition structures.
Handling Revenue enquiries with discretion to minimise business disruption.

Our objective is to protect corporate value while keeping governance and compliance obligations firmly in view.

Acting for Executives & Private Clients

Executives, entrepreneurs, and private clients may also face contentious tax issues with personal consequences. We advise on:

Revenue investigations into residency, domicile, and remittance basis taxation.
Disputes over CGT or income tax in share and property transactions.
Estate and inheritance tax disputes with Revenue.
Defence against penalty or prosecution where allegations of deliberate default are raised.

We recognise the personal pressures these disputes create and provide discreet, supportive representation.

Criminal Tax Investigations

When Revenue suspects fraud or deliberate evasion, disputes may take on a criminal dimension. We have experience in:

Advising during dawn raids and document seizures.
Defending directors and individuals in criminal proceedings arising from tax investigations.
Representing clients facing parallel civil recovery and criminal liability.
Negotiating settlements and engaging with the Director of Public Prosecutions (DPP) where appropriate.

We ensure that clients’ rights are protected throughout every stage of contentious enforcement.

Strategic Approach

Contentious tax matters require more than technical expertise in legislation—they demand litigation strength, commercial sense, and strategic foresight. At Fenecas Law LLP, we emphasise:

Early assessment – Identifying strengths, weaknesses, and settlement options quickly.
Evidence preparation – Working closely with accountants, auditors, and valuers to build strong evidential bases.
Negotiation with Revenue – Exploring settlements where commercially viable, while preparing rigorously for litigation.
Parallel process management – Handling disputes that involve criminal, regulatory, and civil litigation simultaneously.
Confidentiality – Preserving reputation and minimising publicity while disputes are ongoing.

Why Choose Fenecas Law LLP?

Specialist contentious tax expertise – Significant experience in TAC hearings, High Court litigation, and complex Revenue disputes.
Cross disciplinary team – Combining litigation skill with knowledge of corporate, regulatory, and financial law.
Balanced practice – Acting for corporates, institutions, and private clients, giving us a strategic edge.
Commercial focus – Advice rooted in protecting money, reputation, and long term viability.
International reach – Experience with cross border disputes and OECD/EU frameworks.

Contact Us

If you are facing a contentious tax matter—whether as a company, institution, or individual—early legal action is vital to safeguard your financial and reputational interests. Contact Fenecas Law LLP today for strategic advice and strong representation in tax disputes before the Tax Appeals Commission and Irish courts.