VAT and Holding Companies - Review of the Covidien Case - Irish Tax Review PDF | 0.42 MB
Tax partner, Dara Higgins and Tax associate, Freda McGeough recently published an article on the decision of the High Court in The Revenue Commissioners v Covidien Limited [2024] IEHC 192. The case related to the VAT recovery on the costs associated with corporate transactions. The High Court’s decision confirming that VAT recovery was available will be welcomed by taxpayers and practitioners seeking to determine whether a holding company is entitled to VAT recovery in certain circumstances. It 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.
© Copyright of the Irish Tax Institute. This article first appeared in Irish Tax Review, Issue 3, 2024