Revenue has published guidelines in Tax Briefing Issue 04 which outline the circumstances in which Revenue's Large Cases Division (LCD) will provide opinions/confirmations in advance of a transaction.

The guidelines set out the procedures to be followed by taxpayers and agents when requesting an opinion or confirmation from LCD in advance of a transaction/event. In the majority of cases, requests will be dealt with by the Case Manager in the Revenue District in LCD responsible for the taxpayer.

The procedures also provide for consultation, if necessary, by LCD with the Revenue Legislation Service (RLS) before any opinions/confirmations are issued by the case manager in LCD.

For non-LCD cases, the procedures for seeking an opinion/confirmation in respect of a proposed transaction are set out in the Guidelines on Revenue's Technical Service to Practitioners and Business Taxpayers.

The procedures apply to requests for opinions/confirmations received in LCD on or after 9 May 2014.

The guidelines are published in Tax Briefing Issue 04 which is published here.