The Tax and Duty Manual Part 35b-01-01 – Controlled Foreign Company Rules – is now updated to reflect Finance Act 2020 amendments to Controlled Foreign Company (CFC) rules.

Finance Act 2020 inserted section 835YA into Part 35B TCA 1997. Section 835YA TCA 1997 provides that the effective tax rate exemption, the low profit margin exemption, and the low accounting profit exemption will not apply for an accounting period of a CFC where that CFC is resident in a jurisdiction which is listed in Annex 1 of the EU list of non-cooperative jurisdictions for tax purposes.

The amendments take effect in respect of accounting periods of CFCs beginning on or after 1 January 2021.

See eBrief No.027/21 for more information.