The judgment in the case of The Revenue Commissioners v Covidien Limited [2024] IEHC 192 was delivered on 11 April 2024 and upholds the earlier determination of the Tax Appeals Commission (TAC), 81TACD2022, in favour of the taxpayer. There is a large body of case law from the Court of Justice of the European Union (CJEU) endorsing the broad scope of the VAT recovery entitlement for “active” holding companies, but this case is important owing to its particular facts and given the focus on VAT deductibility in respect of the costs associated with corporate transactions. The High Court’s decision will be welcomed by taxpayers and practitioners seeking to determine whether a holding company is entitled to VAT recovery in certain circumstances but also serves as a useful reminder of the importance of ensuring appropriately documented intra-group arrangements to support a claim for VAT recovery for relevant holding companies. The taxpayer’s ability to adduce clear oral and documentary evidence in support of its claim at TAC level was essential to its appeal.