Revenue Note for Guidance

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Revenue Note for Guidance

1036 Control over residents

Where a non-resident, being neither an Irish citizen nor an Irish company or a branch of such a person conducts business with an Irish resident person and the inspector is of the view that because of the close connection between the two, the profits of the Irish resident person are artificially reduced, the non-resident person is assessable and chargeable in the name of the Irish resident as if that person were an agent, etc of the non-resident person.

Relevant Date: Finance Act 2021