Revenue eBrief No. 223/25
27 November 2025
Guidance on the anti-hybrid rules
Tax and Duty Manual Part 35C-00-01 has been updated to reflect changes to the application of the associated enterprises test in relation to partnerships and to confirm that partners in a partnership will always be considered to be “acting together” with respect to the voting rights of shares held through a partnership.
The updates have been made to:
- Section 3.3.2 Having regard to other matters,
- Section 7.3 Application of the "associated enterprises" test to Irish partnerships.