The hearing of the Irish High Court judicial review case brought by US listed company Perrigo (NYSE:PRGO) against the Irish Revenue Commissioners' tax assessment of €1.64bn concluded Friday 12 June 2020 after a seven day hearing.

The High Court will give judgement at a later date. The judge did not give a definitive date for delivery of the judgment. We expect it will take several weeks, but possibly may be delivered at the end of July 2020 which will be the end of the current "legal term" being the normal sittings of the Irish courts before a summer break.

This decision will be awaited with keen interest. The assessment centres around the tax treatment accorded by Perrigo to the sale of a drug as a trading transaction rather than a capital transaction. Perrigo raised issues of legitimate expectation and constitutional rights in the hearing.

If you wish to discuss this matter in more detail, please contact any member of the Maples Tax group.