Revenue eBrief No. 023/26
28 January 2026
Tax and Duty Manual Part 33-01-01 - Main Purpose Tests
Tax and Duty Manual Part 33-01-01 - Main Purpose Tests has been amended by the insertion of Section 2.1.1, to provide guidance on the application of the 'Reasonable to Consider' test. This new section reflects Section 10.1 of Tax and Duty Manual Part 35C-00-01 which provides guidance on the anti-hybrid rules. Section 2.1 has also been updated to provide clarification on the application of objective tests.