Revenue eBrief No. 012/26
15 January 2026
Certain Settlements made by Close Companies
Tax and Duty Manual 13-02-07 - Certain settlements made by close companies - contains guidance on the provisions in section 436A of the Taxes Consolidation Act 1997 and how they apply to the transfer of funds from close companies using trusts and other arrangements. The section counters attempts to transfer funds from close companies on a tax-free basis to shareholders or family members.
The guidance has been updated to restructure the content and to provide additional information and examples on the operation of these provisions.