Irish Revenue has issued eBrief No. 303/24 on updated guidance on anti-hybrid rules.
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Revenue eBrief No. 303/24 Guidance on Anti-Hybrid Rules
Tax and Duty Manual Part 35C-00-01 Part 35C-00-01 has been updated as follows:
- Section 1: Introduction to hybrid mismatches, to clarify that OECD guidance on hybrid mismatches cannot be relied upon to disapply the hybrid mismatch rules in ATAD2, as transposed into Part 35C.
- Section 2: Mismatch outcomes, updated to introduce the concept of prim…