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Ireland Provides Guidance on Attribution of Profits to a Branch

15 September 2022

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Approved Changes

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Ireland

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. --- 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 company operating in the State. The new section 25A applies for accounting periods commencing on or after...