Revenue has updated the Tax and Duty Manual which explains some of the key definitions and terms used in the close company provisions in Part 13 TCA 1997. The guidance now outlines how, in certain circumstances, taxpayers can seek agreement from Revenue that the close company legislation will not apply to an Irish resident company where the ultimate ownership and control of the company is widely dispersed among a large number of investors in funds operated through a limited partnership structure (paragraph 1).
The details to be submitted to Revenue for the request to be considered are also outlined in the manual. With effect from 2 December 2024, these requests must be submitted via the Revenue Technical Service in accordance with the procedures set out in its guidelines.
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