Irish Revenue has issued eBrief No. 127/22, announcing an update to the Tax and Duty Manual on correlative adjustment claims under Article 9 (Associated Enterprises) of Ireland's tax treaties. This Tax and Duty Manual sets out the basis on which a company can claim a correlative adjustment, that the claim will be reviewed by Revenue, and the options available to the company when the review is completed.
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Revenue eBrief No. 127/22 Guidelines for Article 9 Correlative Adjustment claims
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