Chartered Accountants Ireland, as a member of CCAB-I, has responded to the Department of Finance consultation on the tax residency rules. CCAB-I are strongly of the view that the tax residency rules as currently framed are robust, clear and fair and we do not believe that any fundamental recasting of the rules is necessary. Also, CCAB-I wrote to Minister Hayes regarding the promised consultations on the reform of the Office of the Appeal Commissioners in early 2012 which to date have not commenced.

The CCAB-I response to the consultation on the tax residency rules highlights:

• CCAB-I's view is that the rules which determine whether an individual is tax resident or ordinarily resident in Ireland as set out in Part 34 Taxes Consolidation Act 1997 are clear, robust and fair.
• We do not consider that there is a case in fact for a fundamental recasting of the rules governing the residency of individuals.
• We do not believe that the concept of citizenship is an appropriate driver for the charge to taxation, and we are very strongly of the belief that residency, however defined, is a more appropriate criterion.
• Any changes to our residency rules, and the effect of these changes, need to be measured taking account of their impact on and interaction with international tax treaties.

CCAB-I has also recently written to Minister Hayes regarding the promised reform of the Office of the Appeal Commissioners. Following the meeting between CCAB-I representatives and Minister Hayes in November last, we understood that the Minister would conduct consultations on reform of the Office of the Appeal Commissioners in early 2012. It is of concern to us that these consultations have not yet commenced and we have recently written to Minister Hayes to request that these promised consultations be revisited as a matter of urgency.

Readers can access the CCAB-I response to the consultation on the tax residency rules and the CCAB-I letter to Minister Hayes regarding the reform of the Office of the Appeal Commissioners from our dedicated tax representations section on the Chartered Accountants Ireland website at http://www.charteredaccountants.ie/Members/Technical/Tax/Representations/