Revenue eBrief No. 065/26
30 March 2026
Outbound payments defensive measures
Tax and Duty Manual Part 33-05-01 - Outbound payments defensive measures - has been updated as follows:
- New section 3.4.2 has been included concerning the application of the association test for Irish partnerships,
- New examples 3.4.3 and 3.4.4 have been included for associated entities and Irish partnerships,
- Updates concerning association via individual(s), now included in section 3.4.5, and new examples are included,
- Guidance and examples in section 3.8 'Excluded payment' has been updated to confirm that Net CFC Tested Income tax (NCTI) under US tax law is considered to be similar to the controlled foreign company charge for the purposes of the outbound payment defensive measures,
- The text in '5.1.2 - Example - payments to tax transparent entities, generally' has been updated,
- The text in '5.1.4 Example - fund structure' has been updated,
- A new section '5.1.5' has been included with examples concerning Investment Limited Partnerships.
A number of other minor amendments have been reflected throughout the TDM.