Irish Revenue has issued eBrief No.117/23 concerning new guidance to provide clarity on the approach taken by Revenue when classifying a foreign entity for the purposes of Irish tax law, Tax and Duty Manual (TDM) Part 35C-00-02 - Foreign Entity Classification for Irish Tax Purposes. --- Introduction Where a foreign entity is involved in a transaction, the classification of that foreign entity can be central in determining any Irish tax implications. In an Irish tax context, there are fundamentally two entity classifications; entities which are opaque for tax purposes, such as Irish companies, and entities which are transparent for tax...