Payment Notices

Where Revenue successfully challenge certain transactions in a case before the Appeal Commissioners, then Revenue may issue a "payment notice" to the particular taxpayer involved and to any other taxpayer who has claimed a tax advantage as a result of the scheme involved or a substantially similar scheme.

A payment notice may only issue if the scheme:

  • Was successfully challenged on the grounds that it was a tax avoidance transaction for the purposes of section 811C Taxes Consolidation Act 1997, or
  • Was successfully challenged on the grounds that it failed to comply with a specific anti-avoidance provision ("SAAR") listed in Schedule 33, Taxes Consolidation Act 1997, or
  • Was, or should have been, allocated a Transaction Number under the Mandatory Disclosure regime.

This legislation governing payment notices is contained in:

  • Chapter 4 of Part 33 Taxes Consolidation Act 1997

January 2016


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