Irish Revenue has issued eBrief No. 137/22, regarding updated guidance on anti-hybrid rules.
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Revenue eBrief No. 137/22 Guidance on the Anti-hybrid rules
Tax and Duty Manual Part 35C-00-01 - Guidance on the Anti-hybrid rules - has been updated for Finance Act 2021 to reflect amendments to:
- Section 3: Interpretation (Section 835Z) for the broadening of the definition of "entity" to include forms of business that do not have legal personality,
- Section 5: Worldwide system of taxation (S…