Ms Josephine Feehily:

My instinct and experience, because I cannot provide figures here and now, suggest there is more of it now than there was. There is more tactical appealing than there was in the past. I want to be very clear it is very important for proper governance of the tax system that there is a good appeal system and that taxpayers can challenge. Some of the appeals are absolutely appropriate. They take a number of years as fine points of tax law and tax complexity are tested and resolved, sometimes in our favour and sometimes in favour of the taxpayer. At the end of the process we have the clarity we had been missing. It is very important work and it is important that it happens. It will take time. In some cases an appeal can end up in the European courts and one such case is in the report. A rigorous appeal system is important, but from Revenue's point of view it is our job to draw attention to our concerns.