Ireland Tax Agency Updates Guidance on Defensive Measures for Outbound Payments

The Irish Revenue Commissioners March 30 issued Revenue eBrief No. 065/26, and updated guidance on defensive measures for outbound payments. The updated guidance includes: 1) new information on the application of the association test for Irish partnerships that don’t have separate legal personality, with examples; 2) new information concerning association through individuals, clarifying when two entities are considered associated under Taxes Consolidation Act 1997 with respect to relevant payments or distributions made on or after Jan. 1; 3) clarification concerning excluded payments, that net controlled foreign corporation (CFC) tested income tax (NCTI) under U.S. tax laws is considered similar to ...