Irish Revenue has issued eBrief No. 039/22 regarding updated guidance regarding the defensive measures added to the CFC rules by Finance Act 2021, which are targeted at jurisdictions listed by the EU as non-cooperative. The defensive measures disapply the effective tax rate exemption, the low profit margin exemption, and the low accounting profit exemption so that an Irish resident company with a CFC resident in a listed jurisdiction may not avail of these exemptions.
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Revenue eBrief No…