Irish Revenue has issued updated guidance on the tax treatment of Investment Limited Partnerships (ILPs) in eBrief No. 87/2026, reflecting changes introduced by the Finance Act 2025 and setting out revised withholding tax and compliance rules in new TDM Part 27-01a-04.

RF Report

Irish Revenue has issued eBrief No. 87/2026 on 29 April 2026, providing updated guidance on the tax treatment of Investment Limited Partnerships (ILPs). The update is set out in the newly created Tax and Duty Manual (TDM) Part 27-01a-04.

ILPs are regulated investment fund structures formed under a contract between general partners, with unlimited liability, and limited partners, with restricted liability. The updated guidance clarifies the tax treatment depending on the date of authorisation, along with withholding tax rules and compliance obligations, including changes introduced by the Finance Act 2025.

Investment limited partnerships

Tax and Duty Manual (TDM) Part 27-01a-04 relating to investment limited partnerships has been created and sets out:

  • the tax treatment of investment limited partnerships under section 739J of the Taxes Consolidation Act (TCA) 1997;
  • the dividend withholding tax treatment of investment limited partnerships following the passing of Finance Act 2025;
  • the withholding tax treatment of interest payments made to investment limited partnerships;
  • detail relevant to investment limited partnerships with respect to the definition of “collective investment scheme” in Chapter 10A of Part 35C TCA 1997; and
  • the changes to the compliance obligations of investment limited partnerships following the passing of Finance Act 2025.

Overall, the guidance confirms the tax-transparent nature of ILPs and explains how profits and losses flow directly to partners based on their individual tax positions, particularly for partnerships authorised after February 2013, which are outside the standard gross roll-up regime.

Earlier, Irish Revenue released eBrief 022/26 on 3 February 2026 and eBrief 028/26 on 28 January 2026, providing updated guidance on accelerated capital allowances extended by the Finance Act 2025.