Revenue eBrief No. 255/23

08 December 2023

Investment Undertakings

Tax and Duty Manual Part 27-01A-02 Investment Undertakings has been updated:

• To make reference to the Pan-European Pension Product (PEPP) provisions introduced by section 21 Finance Act 2022, and
• To remove references to Approved Minimum Retirement Funds (AMRFs), reflecting Finance Act 2021 amendments.

In addition, the following material updates have been made:

• Contact information for Large Corporates Division has been updated on page 7;
• Footnote on page 22 clarifies that section 189 relief does not extend to the Estate of an individual upon death, who during their lifetime was entitled to section 189 relief;
• Removal of guidance detailing Revenue powers of audit/inspection, as more detailed guidance regarding Revenue Compliance Interventions can be found on the Code of Practice and Compliance section of the Revenue website.

The following Appendices have also been removed:

• Appendix III which referred to “IFSC Funds - Transitional arrangements”; and
• Appendix IV which referred to “Definitions of Intermediary and Residence”, replaced by inclusion of links to the appropriate TDMs providing additional guidance on residence.