Revenue E-Brief

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Revenue E-Brief Issue 141/19, 22 July 2019

Controlled Foreign Companies

A new Tax and Duty Manual, Part 35b-01-01 has been published in respect of the Controlled Foreign Company (CFC) rules, that were introduced by Finance Act 2018 and take effect from 1 January 2019.

The manual provides an overview of what the CFC rules mean and how they operate. It sets out information in relation to what a CFC is, the meaning of ‘control’ and ‘associated companies’, how a CFC charge can arise and the relevant exemptions and reliefs.

22 July 2019