How to Appeal a Revenue Decision in Ireland (2026 Guide)

If Revenue has issued you with an assessment, surcharge or penalty you believe is wrong, you have the legal right to challenge it. Under Part 40A of the Taxes Consolidation Act 1997, any taxpayer aggrieved by a Revenue decision can appeal to the Tax Appeals Commission — an independent statutory body that decides tax disputes separately from Revenue.

This guide explains exactly how to do it, what the deadline is, what your notice of appeal must contain, and how to lodge it correctly.

Who Can Appeal?

Any person who is aggrieved by a Revenue assessment, determination or decision may appeal. This includes:

• Individuals disputing an income tax or PAYE assessment
• Self-employed people challenging an estimated assessment
• Businesses appealing a VAT or Corporation Tax determination
• Anyone disputing a Capital Gains Tax or Capital Acquisitions Tax assessment
• Taxpayers challenging a surcharge or penalty imposed by Revenue

You do not need to be represented by an accountant, tax adviser or solicitor. You can appeal yourself.

What Can You Appeal?

You can appeal any Revenue assessment or decision you disagree with, including situations where:

• The assessment is excessive — Revenue has assessed an amount higher than your actual liability
• Expenses were wrongly disallowed — allowable business expenses were not accepted
• Reliefs or credits were not granted — you are entitled to a relief that was not applied
• An estimate does not reflect reality — Revenue estimated your income without sight of your actual figures
• A surcharge was wrongly applied — a late filing surcharge was imposed but your return was filed on time, or in other circumstances you dispute
• A penalty is disproportionate — the penalty levied is not warranted or is excessive
• Income was wrongly attributed — income has been attributed to you that is not yours
• A valuation is disputed — Revenue used a property or asset valuation you believe is incorrect

The 30-Day Deadline — What You Need to Know

Under section 949I of the Taxes Consolidation Act 1997, a notice of appeal must generally be made within 30 days of the date of the notice of assessment or decision.

This is a hard deadline. The date that counts is the date printed on Revenue's notice — not the date you opened it or the date you received it.

If you are outside the 30 days, you can still apply to the Tax Appeals Commission for a late appeal. The Commission has discretion to accept a late appeal in certain circumstances, but acceptance is not guaranteed. It is always safer to act within the 30-day window.

What Must Your Notice of Appeal Include?

A valid notice of appeal under section 949I should include:

1. Your full name and address
2. The Revenue assessment or decision reference number — printed on Revenue's notice
3. The tax head and period — e.g. Income Tax, Year of Assessment 2023
4. The amount assessed or disputed
5. Your grounds of appeal — the specific reasons you are appealing, set out clearly and separately
6. A statement that the appeal is made within the 30-day time limit
7. A request that the assessment be reduced, discharged or varied

The most important element is the grounds of appeal. Simply saying "I disagree" is not enough — the Commission decides the appeal by reference to the grounds you state. Each ground should be set out as a separate paragraph.

How to Lodge Your Appeal

Once your notice of appeal is drafted, you can submit it to the Tax Appeals Commission in two ways:

Online

The Tax Appeals Commission has an online submissions portal at taxappeals.ie. You can upload your notice of appeal as a PDF or typed document.

By Post

Send your notice of appeal by post to:

Tax Appeals Commission
Fitzwilliam Court
Leeson Close
Dublin 2
D02 YW24

If posting, allow sufficient time for delivery within the 30-day window. Recorded delivery is advisable so you have proof of submission.

What Happens After You Lodge Your Appeal?

Once the Tax Appeals Commission receives your appeal, it is formally registered. Revenue is notified. The Commission will then manage the process, which may include:

• A request for further information or documentation from you or Revenue
• An attempt at settlement between you and Revenue
• A hearing before a Commissioner if the matter cannot be settled
• A written determination (decision) from the Commissioner

Many appeals are resolved without a formal hearing. The important thing is to get a properly-grounded notice of appeal on record before the 30-day deadline.

Do I Need a Tax Adviser?

For straightforward disputes — an excessive assessment, a surcharge you disagree with, expenses that were disallowed — you do not need professional representation. The law allows you to appeal yourself, and a clear, well-drafted notice of appeal is the most important step.

For complex or high-value disputes involving legal interpretation, business valuations or large penalties, consulting a qualified tax adviser or solicitor is worthwhile. But for most individual taxpayers, a properly structured notice of appeal is enough to get the process started.

Frequently Asked Questions

Can I appeal a PAYE determination?

Yes. PAYE assessments and determinations are appealable to the Tax Appeals Commission under Part 40A of the Taxes Consolidation Act 1997, subject to the same 30-day deadline.

Can I appeal a Revenue audit result?

If a Revenue audit results in a formal assessment or determination, that assessment is appealable. The grounds and process are the same as for any other Revenue assessment.

What if I already paid the tax but still want to appeal?

Payment of a tax liability does not prevent you from appealing the assessment. You can appeal even if you have already paid, provided you are within the 30-day window. If your appeal succeeds, Revenue must refund the overpayment.

Is there a risk in appealing?

Lodging a notice of appeal does not increase your liability. The Commission considers the appeal on its merits. In most cases, the worst outcome of lodging an appeal is that it is not upheld — your liability remains as assessed.