On 1 February 2023, the Irish Revenue issued eBrief No. 025/23 regarding charges on income for corporation tax purposes. Accordingly, Tax and Duty Manual Part 08-02-01 has been updated. The updates include the following sections:
- In section 2.2, to refer to the treatment contained in Tax and Duty Manual Part 08-03-06 for relief from withholding tax provided for by double taxation treaties; and
- In section 3.4, to clarify that where a merger or division involves the dissolution of the investing company or the investee company, the fundamental conditions for relief, as provided by section 247 Taxes Consolidation Act 1997 will not be satisfied and relief will cease to be available.
