Mr. Mark O'Mahony:

The taxpayer has the option to pay the tax in dispute while an appeal is pending, but he or she is not obliged to do so. If the person pays the tax then obviously there is no interest charged at the conclusion of the appeal if he or she is unsuccessful. If the appeal is successful, however, then the Revenue Commissioners refunds the tax that has been paid. If the person had not paid the tax then statutory interest is accrued if the appeal is ultimately found to be unsuccessful.