Ireland Tax Agency Issues Guidance on General Anti-Avoidance Rule, Protective Notifications

The Irish Revenue Commissioners April 16 issued Revenue eBrief No. 085/25, providing guidance on the general anti-avoidance rule (GAAR) and protective notifications, under Sections 811C and 811D of the Taxes Consolidation Act 1997, respectively. Topics covered include: 1) the application of GAAR to tax avoidance transactions involving taxes such as corporate income, individual income, and capital gains, but excluding pay-related social insurance, excise tax, and customs duties; 2) the lack of a time limit for the Tax Agency to inquire into whether a transaction is a tax avoidance transaction, to withdraw a tax advantage, or to recover tax; 3) the ...