Irish Revenue has issued eBrief No. 027/21 concerning updated guidance on the controlled foreign company rules.
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Revenue eBrief No. 027/21 Controlled Foreign Company Rules - Finance Act 2020 amendments
Tax and Duty Manual Part 35b-01-01 has been updated to reflect amendments to Controlled Foreign Company (CFC) rules that were introduced by Finance Act 2020.
A new section 835YA in Part 35B of the Taxes Consolidation Act 1997 provides that section 835T (effective tax rate exemption), …