Revenue eBrief No. 023/21

05 February 2021

Distributions

Tax and Duty Manual Part 06-02-02 - Distributions - has been updated as follows:

  • Part 1: Overview now includes an additional paragraph which states that UK companies will continue to be within the ambit of section 130(2(d)(iv) and 130(3) of the Taxes Consolidation Act 1997 following the withdrawal of the UK from the European Union
  • Part 4: Paragraph 12(d) now includes companies resident in the UK in circumstances where interest paid to companies is not to be treated as a distribution per section 130(2)(d)(iv) of the Taxes Consolidation Act 1997.