Rejected VAT Registration in Ireland: What You Can Do

Last reviewed 9 October 2026. General guidance, not advice on a specific set of facts. Nathan Trust is regulated by Chartered Accountants Ireland.

Revenue's letter tells you what kind of rejection you have. The application may have been returned because it was incomplete or sent by the wrong route, or disallowed because a query went unanswered. Or it may have been refused because Revenue is not satisfied the company is making taxable supplies in Ireland, which can be appealed to the Tax Appeals Commission within 30 days of the date of the notice. These can be solved by answering Revenue or by filing a new application backed by evidence of real activity in Ireland.

For founders who are non-residents of Ireland, Nathan Trust works out what went wrong and files the corrected application, including any repair to the company set-up behind it.

What kind of rejection did you receive?

Revenue's Tax and Duty Manual on VAT registration (last updated May 2026) sets out the outcomes an application can have.

Nathan Trust analyzes the letter of rejection alongside the application as filed and the company's records, because the same sentence in a refusal can come from several different gaps.

Why do non-resident applications get refused?

The test is whether the applicant is or will become an accountable person, meaning someone required to charge VAT on taxable supplies in the State. Revenue's manual calls this the main priority when appraising an application, and cites section 5(1)(a) of the VAT Consolidation Act 2010 when it disallows one.

Repeating an application unchanged fixes none of these. Simmons & Simmons reports a 2025 determination in which the company was on its fifth application, and the Commission upheld the refusal because it lacked substantive documents such as contracts or proof of ongoing activity.

Several of these gaps trace back to formation, where a registered office and a certificate of incorporation may be all that exist. Nathan Trust looks at how the company was formed and tells you which of these gaps your application shows.

Should you appeal or reapply?

An appeal must be made within 30 days after the date of the notice, under section 119(2) of the VAT Consolidation Act 2010, by sending a Notice of Appeal to the Tax Appeals Commission together with a copy of the refusal, as Revenue's template refusal letter explains.

The choice is dependent on whether the evidence existed when you applied. If it did and Revenue never saw it, appeal. If it did not, file a new application, because Revenue's manual frames the test as the applicant's position at the time of application. The 30 days run either way, so decide inside them. Nathan Trust will tell you which applies and how many days remain before anything is filed.

Which form and route should the new application use?

Choosing the wrong channel is a cause of rejection in its own right. Revenue's manual returns paper applications from applicants who could have applied online, and its registration guidance (published 6 October 2026) sets out who files where.

A company whose directors all live outside Ireland files on paper, because a director resident in another EEA state is still not an Irish-resident director. Non-resident applicants fall outside the online process altogether, so their supporting documents travel with the paper form rather than going through an upload screen.

Nathan Trust prepares and files the TR2 or TR2(FT) and acts as the Irish contact for Revenue's queries, so a follow-up letter gets an answer and doesn't turn into a second disallowance.

How does Nathan Trust fix a rejected VAT registration?

If your company was formed by a provider that stopped at the Certificate of Incorporation, the VAT application is where Revenue tests what the formation left out. A certificate shows the company exists. It doesn't show the company trades.

We start by reading the Revenue letter next to the application as filed and the company's records, including the CRO filings. Then we tell you which kind of rejection it is, and whether the company needs an Irish VAT registration at all. Sometimes the answer is no. Where the cause sits in the company set-up, we repair it: the registered office, the director arrangements including the Section 137 bond, the directors' PPS numbers or Identified Person Numbers and an Irish bank account. With the company in order, we assemble the evidence pack and file the TR2 or TR2(FT) by the right route. We deal with Revenue's queries or caseworker visit until the number issues, then set up ROS filing and take on your VAT returns if you want them handled.

Send us the refusal letter and the application you filed through our VAT registration service, and we will tell you where it went wrong and what the corrected application needs. If the company has not been formed yet, our guide to what Revenue needs from foreign-owned companies before they apply covers prevention.

Frequently asked questions

Can I reapply after Revenue refuses my VAT registration?

Yes, with evidence that did not exist before. Resubmitting the same application unchanged does not help.

How long do I have to appeal a VAT registration refusal?

30 days after the date of the notice, under section 119(2) of the VAT Consolidation Act 2010. The appeal goes to the Tax Appeals Commission with a copy of the refusal.

Does a registered office address count as an Irish presence?

Not by itself. It is the address for company post and filings, and Revenue wants to see where business activity happens. That is why an adviser's address, rented desk space and a consulting agreement together were not enough in the 2025 determination reported by Simmons & Simmons.

Do I need an Irish VAT number if I only sell services to Irish businesses?

Often not. For most business-to-business services the Irish customer accounts for VAT under the reverse charge. A non-established business must register regardless of turnover where it supplies goods in Ireland, imports goods, or sells goods at a distance to private customers in Ireland, according to Revenue's guidance for non-established traders (published 10 December 2025).

Sources

• Revenue Tax and Duty Manual Part 38-01-03b, Guidelines for VAT Registration (last updated May 2026)
• Revenue: How do you register for VAT? (published 6 October 2026)
• Revenue: Non-established traders supplying goods and services in Ireland (published 10 December 2025)
• VAT Consolidation Act 2010, section 119
• EY Ireland: VAT Registrations, Practical challenges and pitfalls (27 June 2024)
• Simmons & Simmons: VAT Registration in Ireland, Lessons from recent cases (8 October 2025)