Courts / Dublin / Report

AbbVie brings 'precautionary' action over €587m tax bill

Summary

Pharmaceutical company AbbVie has filed a precautionary High Court action against the Revenue Commissioners concerning a €587 million tax bill that arose after its acquisition of Allergen. The bill was originally imposed following a 2020 budget measure that made share‑cancellation schemes liable for a 1 % stamp duty, a change from previous tax exemption. AbbVie contested the assessment, and a Tax Appeals Commissioner (TAC) ruled in its favour, reducing the liability to zero. Revenue appealed the TAC's decision to the High Court, arguing the TAC lacked jurisdiction. AbbVie's counsel, Michael Cush SC, described the action as precautionary, aiming to protect its position should the High Court find the TAC's jurisdiction invalid. The case, heard by Mr Justice Charles Meenan, was granted permission on an ex‑parte basis, with proceedings scheduled to resume in late March.

Who, what, where, when and why

What: Report matter: AbbVie brings 'precautionary' action over €587m tax bill. Procedural stage: hearing_or_decision

When:

• July 2020 Hearing Or Sentence
• 2021-01-18 Publication

Why: Mr Cush said that this application was "precautionary in nature" and was being done in order to protect its position, which he said was vindicated by the TAC. CNI source report

Case subjects

Places mentioned

Topics

Stage Hearing Or Decision

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Read the original CNI report