Revenue has updated its Tax and Duty Manuals concerning the taxation of Offshore Funds.
The updated manuals include a non-exhaustive list of general legal and regulatory criteria that should be considered to assist in establishing whether an offshore fund may be considered ‘similar in all material respects’ to an Irish fund.
The manuals are also updated for amendments introduced by recent Finance Acts:
- Finance Act 2022 – clarification of the tax treatment of an authorised unit trust.
- Finance Act 2020 – clarification of the interaction of the offshore fund legislation with respect to the migration of Irish securities from the CREST system to Euroclear Bank in March 2021 following BREXIT.
Further information is available in eBrief no. 081/23.