Ireland Updates Guidance on Main Purpose Tests in Relation to Anti-Avoidance Rules Including New DAC6 Requirements

Irish Revenue has published eBrief No. 029/20 on updated guidance on main purpose tests.

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"Main purpose" tests

Many sections of the taxing statutes include a “main purpose test”, particularly in the anti-avoidance sections. Revenue Tax & Duty Manual Part 33-01-01 summarises case law in the area.  The manual has been updated to include a reference to the EU mandatory disclosure regime, which comes into operation on 1 July 2020 and includes a “main benefit test”.

The new…