Revenue has updated the
Tax and Duty Manual regarding Controlled Foreign Company (CFC) Rules. The manual has been updated to reflect the Finance (No.2) Act 2023 amendment to
section 835YA TCA 1997 concerning Irish defensive measures in respect of the CFC rules. Revenue has advised that this manual will be further updated to reflect Pillar Two related consequential amendments made to the CFC rules in Finance (No. 2) Act 2023.