Irish Revenue has issued eBrief No. 179/19 on new guidance concerning the new tie-breaker rule under BEPS MLI for dual-resident companies.
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Dual-Resident Companies
A new Tax and Duty Manual Part 35-01-11, Dual-Resident Companies, has been created which outlines the new rule under Article 4 of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ('the MLI') regarding the residence for treaty purposes of companies which are resi…