The time-limit provisions contained in the Taxes Consolidation Act 1997 (TCA 1997) serve an important role in providing certainty and safeguarding taxpayers against the reopening of their tax affairs outside a four-year period. The exact construction of these provisions has, however, been the source of many disputes between taxpayers and the Revenue Commissioners (Revenue), that ultimately have been resolved by the Superior Courts. O’Sullivan v The Revenue Commissioners [2024] IEHC 611 is the most recent judgment in the area and provides some welcome insights into the proper construction of the provisions, particularly in light of the judgment of Mulcahy J in Tobin v The Revenue Commissioners [2024] IEHC 196 earlier this year.
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