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.
Revenue's Tax and Duty Manual on VAT registration (last updated May 2026) sets out the outcomes an application can have.
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What the letter says |
What it means |
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The form is returned with a list of missing information |
Not a refusal. The form was incomplete, for example unsigned, or missing the CRO number, the directors' PPS numbers or the shareholder details |
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A paper application is returned with a request to apply online |
The applicant is not in a category that may file on paper |
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The application is disallowed because an enquiry letter was not answered |
Revenue asked for information and received no reply |
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The application is refused because Revenue is not satisfied the applicant is an accountable person, or that taxable supplies are being made |
Revenue found no objective evidence of taxable activity |
Revenue's manual describes VAT registration as a high-risk area because of the potential for bogus traders, and says a Revenue caseworker should visit wherever there is doubt that a genuine business exists. EY's review of registration problems (June 2024) describes the pattern that raises that doubt: a newly incorporated company with a CRO registration and no real presence in Ireland.
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.
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.
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The gap |
What Revenue's guidance says |
How to close it
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Only a certificate of incorporation, with no contracts, invoices, premises or tools of the trade |
A business that has not started to trade can register on satisfactory evidence that it will become an accountable person, such as leases, contracts and tools of the trade |
Assemble that evidence before reapplying |
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A registered office as the only Irish address |
The manual lists a lease, or evidence of efforts to secure premises, as proof of a business address. In a 2025 Tax Appeals Commission case reported by Simmons & Simmons, a registered address at the tax agent's office, rented desk space, a consulting agreement and bank statements did not show taxable activity in Ireland |
Show where the work happens in Ireland, not only where the post arrives |
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Intra-EU status requested with little detail |
Intra-EU applicants must give transport arrangements, the nature of their supplies and acquisitions, and the due diligence they carry out on customers and suppliers |
Describe the supply chain and who ships the goods, and say how you check trading partners |
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No Irish registration was needed |
For most business-to-business services the customer accounts for VAT under the reverse charge, so a non-established supplier of services to Irish businesses may have nothing to register for |
Confirm the obligation exists before spending on evidence |
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An enquiry letter went unanswered |
Revenue disallows an application where its enquiry has not been answered |
Name someone in Ireland who reads Revenue's correspondence and replies inside the deadline |
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.
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.
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.
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Applicant |
Form |
Route
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Irish company with at least one Irish-resident director |
TR2 |
Online through eRegistration in ROS |
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Irish company with no Irish-resident director |
TR2 |
Paper, to Business Registrations at Revenue's Wexford office |
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Company not established in Ireland |
TR2(FT) |
Paper, to Business Registrations at Revenue's Wexford office |
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.
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.
Yes, with evidence that did not exist before. Resubmitting the same application unchanged does not help.
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.
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.
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).