Irish Revenue has issued eBrief No. 120/26 on updates to Tax and Duty Manual Part 04-09-01 - Section 110: entitlement to treatment. Section 110 of the Taxes Consolidation Act (TCA) 1997 provides rules for a Section 110 company (a qualifying company), which is a specialized Irish corporate structure designed to facilitate international corporate finance, structured finance, and securitization transactions by providing a tax-neutral framework within Ireland. The update concerns the applicatio…