In 2017, Irish Revenue published an eBrief regarding the period of validity of opinions and confirmations. Revenue will only provide an opinion or confirmation for complex issues, where information is not readily available or where there is genuine uncertainty regarding applicable tax rules. An opinion or confirmation represents Revenue’s view of the application of tax law to a particular transaction.
The maximum period for which the opinion or confirmation may remain valid without review is five years. However, Revenue may specify a shorter period. An opinion or confirmation will only remain valid as long as the facts and circumstances have not changed and the relevant legislation remains in place. Revenue can, however, review at any time, with a view to amendment or withdrawal.