Irish Revenue has issued eBrief No. 023/26 concerning updates to Tax and Duty Manual Part 33-01-01 - Main Purpose Tests to clarify the application of objective tests (Section 2.1) and to include new related guidance on applying a 'reasonable to consider' test (Section 2.1.1). The schedule of updates and the relevant guidance is as follows:
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Appendix A - Schedule of material updates
January 2026
Section 2.1 was updated to clarify that "In applying objective tests, there can be no art…