On 29 March 2021, the Irish Revenue published an eBrief No. 068/21 to announce a manual to update the guidance on anti-hybrid rules. On the similar day, the Revenue also published a Tax and Duty Manual, which provides guidance on the anti-hybrid rules, has been updated to include:
- amendments made by Finance Act 2020 to how the anti-hybrid rules apply to worldwide systems of taxation,
- key terms used in the anti-hybrid rules such as “payee”, “reasonable to consider” and “associated enterprise”, and
- the “imported mismatch” rule.
