Somewhat unusually, Revenue have also published their response to the consultation on reform of the Appeals Process. While input on public consultations is usually available after the event via the Freedom of Information process, it’s useful to have the comments of Government agencies at an earlier stage.

Proposals made by Revenue include:

• The new structure should comprise three full-time commissioners with adequate administrative support and other resources.
• Provision should be made for temporary appointments of Appeal Commissioners.
• The Appeal Commissioners should have full control of the process by which appeals are lodged and heard.
• Any administrative arrangements that could be perceived to undermine the independence of the Office of the Appeal Commissioners should be reviewed.
• The Appeal Commissioners should issue a concise reasoned determination in writing in all cases within a relatively short period of time, ideally three months.
• The Appeal Commissioners should take full control of the record of their determinations and make them available to both the taxpayer and Revenue as of right within a specified period of time.

There are also some broader observations on appeal mechanisms and the legal form of hearings, which if implemented would have significant consequences for the cost and conduct of appeals. The full Revenue document is available on their website.