Opinions and confirmations issued by Revenue in the period between 1 January and 31 December 2012 are now subject to review. If you or your client wants to continue to rely on any opinion or confirmation issued by Revenue during this period, in respect of a transaction, period or part of a period, on or after 1 January 2018, you will need to make an application for its renewal or extension on or before 30 March 2018.

Generally the maximum period an opinion or confirmation is valid without being reviewed is 5 years. However, in some cases, a shorter period may be specified by Revenue. To continue to rely on an opinion or confirmation, the following must be done by 30 March 2018:

1. Supply evidence of the opinion/confirmation, being a copy of a written communication which originated from Revenue, and
2. Lodge a full application for the renewal or extension of the opinion/confirmation with the Revenue District dealing with the taxpayer’s affairs. The application must be made in full compliance with existing Revenue procedures in relation to obtaining an opinion/confirmation from Revenue, as contained in Tax and Duty Manuals Part 37-00-40 and Part 37-00-00a.

For more details, read the Revenue Tax and Duty Manual Part 37-00-41.