Doubt about the VAT treatment of a transaction

What is an expression of doubt for Value-Added Tax (VAT) purposes?

You may lodge a letter of ‘expression of doubt’ with Revenue, relating to the application of VAT law to a transaction. This can include doubt regarding the rate of VAT to apply to a transaction.

Revenue will notify you if your 'expression of doubt' is not accepted as genuine.

If it is accepted as genuine, Revenue will inform you of the law applied to the matter about which you have expressed doubt. Following receipt of our reply, an additional liability may arise. You should pay any further liability in the taxable period during which the notification is received.

Where you have paid additional tax, relating to the ‘expression of doubt’ as set out above, interest will not be applied to that liability.

Can you appeal Revenue’s refusal to accept an expression of doubt?

If Revenue refuses to accept that the expression of doubt is genuine you may appeal to the Tax Appeal Commissioners.

Further guidance contains more detailed information on expression of doubt submissions.