Revenue has updated the Tax and Duty Manual on the Controlled Foreign Company (CFC) rules to includes changes made in the Finance Act 2024 and Finance Act 2023.
The changes are as follows:
- An amendment to the provision providing for the Irish defensive measures in respect of the CFC rules and to include the updated EU Code of Conduct list of non- cooperative jurisdictions for tax purposes
- Amendment to the rules for calculating ‘undistributed income’ of the CFC arising from the introduction of the new corporation tax exemption for certain foreign dividends
- Pillar 2 related amendments to the CFC rules for creditable tax and effective tax rate exemption.
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