Taxpayer’s appeal rights exhausted after he agreed to be bound by decision of Circuit Court

The High Court affirmed the decision of the Appeal Commissioner, finding that the taxpayer had no further right to appeal against the Revenue's amended assessment for tax relief withdrawal. The taxpayer had previously agreed to be bound by a decision of the Circuit Court, which had concluded that the transaction in question was a tax avoidance transaction. The High Court held that the taxpayer's rights to appeal under specific sections of the Taxes Consolidation Act 1997 were expressly excluded by subsequent legislative amendments and the terms of the settlement agreement.