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2.������ The four applications relate respectively to France, Germany, the Republic of Korea and Iceland.� A further application was instituted [2020 No. 89 MCA] regarding Australia, but that was struck out by consent with no order.
3.������ I have received helpful submissions from Ms. Alison Keirse B.L. for the applicant (who is an official of the Revenue Commissioners acting on their behalf) and from Ms. Bernadette Quigley B.L. (with Mr. Frank Mitchell S.C.) for the respondent.
4.������ An application to the court for information from a third-party in relation to the affairs of a taxpayer of the type launched here must be made in camera : s. 902A(7) of the Taxes Consolidation Act 1997.� Prior to instituting the present applications, the Revenue Commissioners obtained orders from Meenan J. on 13th May, 2020 entitled in intended actions, the first one being 2020 No. 33 IA, to anonymise the pleadings.
8.������ Order 84B, r. 2(1) of the Rules of the Superior Courts provides that �Save where the application is authorised by the relevant enactment to be made ex parte , it shall be made by originating notice of motion�.
10.���� In Child and Family Agency v. M.O�L. [2019] IEHC 917 , [2019] 12 JIC 2701 (Unreported, High Court, 27th December, 2019) at para. 13, I noted that originating notices of motion should be headed as such rather than simply as � Notice of Motion �, to distinguish them from a garden variety motion brought within pre-existing proceedings.� On Ms. Keirse�s application I will dispense with that requirement here, but perhaps the correct procedure might be noted by Revenue for future reference.
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