Understanding Ireland’s 2025 Tax Landscape

Key Contacts: Michael McGivern – Head of Tax |

The Revenue Commissioners and the Tax Appeals Commission both recently published their  2025 Annual Reports. For those of us in the tax profession, these always make for interesting reading, and we have set out below some of the more salient aspects contained in each report.  

Revenue Commissioners Annual Report 2025

• In 2025 Revenue collected gross receipts of €157 billion, which included gross tax receipts of €122 billion and €35 billion which Revenue collected on behalf of other government departments, agencies and EU Member States.
• Income taxes remained the highest gross receipt category at €40.7billion, followed by corporation tax at €37.7 billion and VAT at €31.3 billion.   
• Revenue credits its “digital-first” services for high levels of Irish timely tax compliance, which in 2025 stood at 99% for large and medium cases and 93% for other cases. There was also record levels of engagement with Revenue’s online services, with 26.5 million logins to its “myAccount” service and 24.4 million logins to ROS, resulting in electronic payments to the value of €149.1 billion being processed during 2025.
• At 31 December 2025 there were 18,653 phased payment arrangements (PPAs) in place, covering outstanding taxes of almost €1 billion. This includes €708 million of tax debt which was included in the Covid- 19 related Debt Warehouse Scheme (DWS). The vast majority of businesses with PPAs in place to cover warehoused debt are honouring their monthly commitments.
• During 2025 Revenue made 101,090 enforcement referrals which yielded €265.7 million.
• Revenue maintains a robust framework to identify and address non-compliance using real-time data analytics, shared intelligence and technology to quantify, manage and address risk.
• During 2025, Revenue completed 237,550 audit and compliance interventions which yielded €734 million. Revenue also completed 189 what it terms “tax avoidance cases” which yielded €41.7 million.
• During 2025 Revenue also devoted resources to monitoring compliance with the framework on classification of workers for income tax purposes, as set out by the Supreme Court in The Revenue Commissioners .V. Karshan (Midlands) Ltd – the “employed versus self-employed” issue.  
• Revenue notes that at EU level, the adoption of VAT in the Digital Age (ViDA) proposals mark a significant milestone in the transformative journey towards modernisation of VAT administration. During 2025 Revenue published its national implementation plan for a phased transition to mandatory domestic eInvoicing, with a view to helping Irish businesses prepare for EU-wide mandatory requirements which will come into effect in 2030. Phase One of this transition will apply to Large Corporates with effect from November 2028.
• In the international tax landscape, Pillar Two is an ongoing significant issue for large MNEs. In this context Revenue made substantial progress in preparing for the first Pillar Two filings which were due by 30 June 2026. Revenue’s work included deploying systems for registration, developing filing and payment capabilities and preparing for international information exchange.
• Revenue’s workforce currently stands at about 7,000.
• Revenue continues to explore the use of AI, and during 2025 it launched “sandboxed” versions of Large Language Models (LLMs) to assist its personnel in areas such as document summarisation, idea generation and internal code-development and maintenance.

Tax Appeals Commission (“TAC”) Annual Report 2025

To use the TACs own words, the TAC exists to fulfil its obligations under the Finance (Tax Appeals) Act 2015 and the Taxes Consolidation Act 1997, to ensure that all taxpayers may exercise, where appropriate, their right of appeal to an independent body against decisions and assessments of the Revenue Commissioners and the Criminal Assets Bureau.

We would comment as follows in relation to the TAC’s 2025 Annual Report:

• The TAC issued 216 determinations in 2025 (190 in 2022)
• It had 620 open appeals on hand at the end of 2025 with an estimated combined tax value of €544 million. Just three years earlier at the end of 2022, there were 1,504 appeals at hand with an estimated combined value of €1.3 billion. This highlights the speed at which the TAC is now closing appeals in one way or another. We comment more about this below.   
• The TAC had 33 staff at the end of 2025 (same as at the end of 2022) with 8 of these being Appeal Commissioners.
• The TAC received 1,192 new appeals in 2025. Similar to trends in earlier years, 40% of these were income tax related with a combined estimated tax value of €38 million. The next highest category was VRT at 15% (estimated tax value of only €1million), followed by VAT at 12% (combined estimated tax value of €69 million). However by estimated tax value, corporation tax was the highest category with 56 new appeals received with a combined estimated tax value of €492 million.
• The TAC closed 1,286 appeals in 2025. Closures occur under many circumstances including by way of a formal determination of an appeal, settlement between Revenue and an appellant, withdrawal of an appeal by an appellant, refusal of the TAC to admit an appeal, and the merging or dismissal of appeals.
• The TAC notes that 2025 was the seventh year that it closed more appeals than it received, resulting in a fall of 13% in the number of appeals on hand at year end. This again highlights the accelerating pace at which appeals are being closed.   
• Of the appeals closed in 2025, the following statistics are of note when compared to their 2024 equivalents:
  • Settlements: The percentage of settlements has remained largely the same at 36%. This highlights that not all cases will necessarily end up for hearing before the TAC, and that in certain circumstances settlements with Revenue may still be possible, even after an appeal has been formally lodged with the TAC.
  • Appeals refused: The number of appeals refused to be heard by the TAC in 2025 increased from 11% to 13% in 2025. This perhaps highlights the importance of appellants ensuring that they are lodging valid appeals in a timely manner.
  • Cases withdrawn: The percentage of cases withdrawn before a hearing has dropped by 10%.
• Revenue was successful in 92% of the TAC determinations made in 2025. This is up from 86% in 2024 and 81% in 2023. It is difficult to draw definitive conclusions as to why this is the case, and each appeal will have its own features. However, relevant factors are likely to include the quality of technical arguments made by both sides, and the adequacy of supporting documentation and other supporting evidence provided. Also, the high volume of VRT cases may distort the percentage.    
• The TAC received 1,192 new appeals in 2025, which is a 7% reduction on the 2024 equivalent number, and 18% down on 2022. This may be the start of an emerging trend of a reluctance by taxpayers to make tax appeals.   
• In our view, any business contemplating making a tax appeal or currently within the tax appeals process should be mindful of the following:   
  • Professional advice: The business should seek professional advice at the earliest opportunity to adequately manage the demanding and fast paced appeals process.
  • Documentation: The business should ensure that it prepares comprehensive and contemporaneous documentation to support its tax positions. This should be done at the time of the relevant transactions, and will significantly assist with dealing with audits. Documentation is also critical in the context of tax appeals where the burden of proof generally lies with the appellant. In addition as outlined above, the TAC has significantly speeded up the timelines within which tax appeals are being processed, and therefore such documentation must be produced quickly to keep up with this pace.  

Finally, although not addressed in the TAC Report, it is timely to briefly comment on a current ongoing tax appeal issue i.e. the existence of the Finance (Tax Appeals and Fiscal Responsibility) Bill 2024 (“The Bill”). The Bill proposes fundamental changes to the tax appeals process as a result of the 2021 Supreme Court judgment in the case of Zalewski v. Adjudication Officer & Ors. Current legislation entitles a taxpayer to have its tax appeals hearing to be held in private. However, among other things, The Bill proposes that instead of giving the taxpayer a mandatory entitlement to a private hearing, the TAC would be given discretion to determine whether the appeal should or should not be heard in private. This proposed change is rightly viewed with considerable concern by both the tax and legal professions and by business. In May 2026, the Oireachtas Joint Committee on Finance, Public Expenditure, Public Services Reform and Digitalisation, and Taoiseach shares this concern, when it stated that it “very much agrees with the consensus of both legal and financial stakeholders that the tax appeal system does not need to be changed, and if it were changed in line with the current proposal it would have an extremely negative impact upon taxpayers’ willingness to seek independent review of Revenue decisions and assessments”. The Committee went on to state that it “is very clear in its view that the proposed change would undermine the appeals process by causing potential appellants not to appeal for fear of personal details or commercially sensitive details being brought into the public domain. To undermine the process and create a fear of appealing defeats the purpose of having an appeals process.” It is hoped that Dail Eireann takes note of these remarks, and that this aspect of The Bill will not proceed.