Revenue eBrief No. 230/25
05 December 2025
Review of Opinions or Confirmations
Tax and Duty Manual Part 37-00-41 - Review of Opinions or Confirmations - has been updated to provide guidance to taxpayers who wish to continue to rely on an opinion or confirmation issued by Revenue in the period between 1 January 2020 and 31 December 2020, in respect of a transaction, period or part of a period, on or after 1 January 2026.
A taxpayer who wishes to continue to rely on such an opinion or confirmation is required to make an application for its renewal or extension on or before 31 March 2026.
The Tax and Duty Manual has also been updated as follows:
- The individual sections dealing with the review of opinions/confirmations issued by Revenue between 2012 and 2019 have been summarised and are now outlined in the table in section 2.3.
- Appendix B – Number of applications received for the renewal or extension of opinions/confirmations issued prior to 1 January 2012 has been removed.