Revenue eBrief No. 234/25
08 December 2025
Material interests in offshore funds
Tax & Duty Manual Part 27-02-01 - Offshore Funds: Taxation of income and gains from certain offshore states, which sets out a summary of some of the key features of the offshore funds regime, has been updated as follows:
- to clarify that a reference to an offshore fund only relates to a foreign company, unit trust scheme or co-ownership arrangement in which a person has a 'material interest',
- to reflect the term ‘reasonably expected’ as per section 743(2), and
- to include contact details in respect of applications to Revenue for certification as a distributing offshore fund.