Revenue eBrief No. 139/25
22 July 2025
Outbound payments defensive measures
Tax and Duty Manual 33-05-01 ‘Outbound payments defensive measures’ has been updated to reflect amendments to section 817U Taxes Consolidation Act 1997 (TCA 1997) implemented by the Finance (Local Property Tax and Other Provisions) (Amendment) Act 2025. The amended provisions of section 817U TCA 1997 are effective from 1 January 2026.
The amendments to 817U TCA 1997 extends the definition of ‘associated entities’ to include entities which are associated by reference to the ownership or control by the same individual, or individuals connected with that individual, within the meaning of section 10 TCA 1997. Updated sections:•Section 3.4 Associated entities, including two new examples.•Additional guidance in example 5.1.4 stemming from the recent amendment.•Miscellaneous minor revisions.