Management of a Revenue Audit resulting in a sustainable settlement, based on clients repayment capacity.

This long-standing client was in the process of finalising a property refinancing to avail of attractive early redemption terms offered by a departing UK bank triggered by the great property crash.


What started out as a routine Revenue audit case, following normal surveillance activity of a trade event in the sector, the Co’s tax-affairs became a multi-faceted series of linked potential liabilities across all taxes.


Over a two year period McGleenan & Co managed the audits technical & negotiation process as follows:


  • Initial meetings with Revenue’s technical personnel were broadened to include site-visits with the client, to get a better appreciation of the features of the business and the personal qualities & integrity of the client Co’s Directors.


  • After a stalemate was reached with Revenue regarding the treatment of five different material mitigating factors that the Co required agreement in order to be in a position to continue trading, Revenue sought a high level one-to-one without prejudice meeting with McGleenan & Co’s principal to establish if agreement without could be reached & the case possibly closed.


  • Revenue’s draft all-in liability was standing at €1.3m however, after a calm & reasonable exposition of all the counter-claims and allowing for a uniquely positive atmosphere following Irelands defeat of Italy the night before in the Euro’s, both sides agreed to an all-in settlement of €360k, payable over five years in line with the Co’s ongoing trading resources.


The outcome to this case shows that in some instances it is better to work “with the grain” where Revenue is concerned. We believe at McGleenan & Co that it is important to assess all options in the broadest terms when negotiating for clients, while acknowledging that Revenue’s perspective is equally important.