Jim O'Callaghan (Dublin Bay South, Fianna Fail) | Oireachtas source

Obviously, members will be aware that a taxpayer who wishes to dispute a tax assessment made by the Revenue Commissioners may appeal to the Tax Appeals Commission. The law at present is that the taxpayer has to pay the tax in advance. The matter is then determined by the Tax Appeals Commission and if the taxpayer is correct and the tax was not payable, the money will be paid back to the taxpayer along with interest at 4%. However, the effect of section 67 appears to be that the Revenue Commissioners would not have to pay interest to a taxpayer who was found to be correct in his or her appeal to the Tax Appeals Commission. Is my reading of the section correct? If so, does the Minister not think there might be an unfairness there in terms of taxpayers having to pay penalties and interest when in the wrong, but when the taxpayer is in the right, there does not seem to be any downside for the Revenue Commissioners?