A previous Custom House had been built in 1707 by engineer Thomas Burgh (1670–1730). However, by the late 18th century it was deemed unfit for purpose.

The building of a new Custom House for Dublin was the idea of John Beresford, who became first commissioner of revenue for Ireland in 1780. In 1781 he appointed James Gandon as architect, after Thomas Cooley, the original architect on the project, had died. This was Gandon's first large scale commission. The new Custom House was unpopular with the Dublin Corporation and some city merchants who complained that it moved the axis of the city, would leave little room for shipping, and it was being built on what at the time was a swamp. Purchase of land was delayed and proved exorbitant and the laying of foundations was disrupted by the High Sheriff and members of the Dublin Corporation with a mob of several thousand. However, Beresford was determined to complete the project and ignored the protests.

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