Revenue eBrief No. 099/24
27 March 2024
Controlled Foreign Company rules
Chapter 11 of Tax and Duty Manual Part 35b-01-01 - Controlled Foreign Company (CFC) Rules, which refers to section 835YA of the Taxes Consolidation Act 1997 and concerns Irish defensive measures in respect of the CFC rules, has been updated to reflect an amendment introduced by Finance (No. 2) Act 2023.
This manual will also be updated in due course to reflect Pillar Two related consequential amendments made to the CFC rules in Finance (No. 2) Act 2023.