Irish Revenue has updated its guidance on outbound payment defensive measures to reflect the 2025 legislative changes to Section 817U of the TCA, effective from 1 January 2026.

Irish Revenue has published eBrief No. 139/25 announcing updates to Tax and Duty Manual 33-05-01 concerning defensive measures on outbound payments on 22 July 2025.

Tax and Duty Manual 33-05-01 ‘Outbound payments defensive measures’ has been updated to reflect amendments to section 817U Taxes Consolidation Act 1997 (TCA 1997) implemented by the Finance (Local Property Tax and Other Provisions) (Amendment) Act 2025. The amended provisions of Section 817U of the TCA 1997 are effective as of 1 January 2026.

The amendments to 817U TCA 1997 extend the definition of ‘associated entities’ to include entities which are associated by reference to the ownership or control by the same individual, or individuals connected with that individual, within the meaning of section 10 TCA 1997.

Updated sections:

  • Section 3.4 Associated entities, including two new examples.
  • Additional guidance in example 5.1.4 stemming from the recent amendment.
  • Miscellaneous minor revisions.