Irish Revenue Updates Guidance on Foreign Entity Classification for Irish Tax Purposes

Irish Revenue has issued eBrief No. 082/26 on updated guidance regarding foreign entity classification for Irish tax purposes. The purpose of the guidance is to provide clarity on the approach taken by Revenue when classifying a foreign entity. Broadly, Revenue's approach is to look at each foreign entity on its own merits and, based upon established principles set out in case law, determine whether the entity is more akin to an Irish company (and opaque) or more akin to an Irish partnership…