Mr. Niall Cody:

The Finance (Tax Appeals) Act provided for a process, which we had to engage with, in respect of each taxpayer for whom an appeal was open. We had to write to each taxpayer and ask him or her a series of questions. Some appeals were in a legacy position and the taxpayers did not realise that they were still open. They had to fill out a questionnaire, the first question on which was whether the appeal was still in existence.

The legislation also provided for an opportunity for agreement between Revenue and the taxpayer about the issue. Subsequently, some practitioners said that they had believed they were going to get an opportunity to reach settlements, but I imagine what they thought was that, if the liability was X amount, we would settle for half of it. We cannot do that, however. We are obliged to interpret and apply the law. What the legislation provided was an opportunity for engagement to see whether there could be agreement around the interpretation of the law or the quantum of the liability. A good number of cases settled at that stage and did not proceed. However, the taxpayer might have replied that he or she was interested in the appeal continuing.

The cases were transferred in three tranches, with the details set out, a spreadsheet all the cases and the notes on each. In the period between the first and final tranches, there was a Supreme Court judgment on a case, which led to the settlement of approximately 100 follower cases. It was a tax planning case that we lost. Those cases had gone over in the first tranche, but they were then withdrawn because the assessments fell.

A process would have been followed at the end of November or December. I have many details on when the cases went over. The final set would have been transferred over and summarised in a final file transfer of all legacy cases-----