Overpayments to revenue not offset due to statutory time limitations

Court of Appeal upholds the High Court's decision that the appellant was not entitled to offset overpayments made to the Revenue Commissioners against sums due, as the claims for set-off were made outside the statutory four-year time limit. The appellant, who operated a sand and gravel business, had failed to file statutory returns for VAT, PAYE, and PRSI between 2003-2010, resulting in overpayments based on estimates served by the Revenue. The appellant's defense was that he was entitled to offset these overpayments against his tax liabilities. However, the court found that the appellant's claims for set-off were time-barred and that the correspondence between the parties could not extend the mandatory statutory period for making such claims. The court also concluded that the appellant had been given credit for certain overpayments, and that the Revenue Commissioners had not erred in their application of payments and credits.