Irish Revenue has issued eBrief No. 166/22 on a new Tax and Duty Manual Part 02-02-04a, which provides guidance on the attribution of profits to a branch.
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Revenue eBrief No. 166/22 Attribution of profits to a branch
Section 28 of Finance Act 2021 inserted a new section 25A into the Taxes Consolidation Act 1997 to provide for the application of an OECD-developed mechanism (the "authorised OECD approach" or "AOA") for the attribution of income to a branch or agency of a non-resident c…