Ireland Tax Agency Issues Guidance on Defensive Measures for Outbound Payments

The Irish Revenue Commissioners March 26 issued Revenue eBrief No. 096/24, and guidance, on defensive measures for outbound payments. The guidance includes: 1) relevant definitions, concepts, and examples; 2) various measures to address payments to tax transparent entities, targeted anti-avoidance provisions, and cases where interest is classified as a distribution; 3) the operation of defensive measures for interest payments, persons liable for withholding tax on outbound interest payments, royalty payments, and the making of a distribution; 4) the application of defensive measures to arrangements entered after Oct. 19, 2023, for payments of interest and royalties, and after April 1, 2024, ...