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Irish Revenue Provides Guidance on the General Anti-Avoidance Rule and Protective Notifications

17 April 2025

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Approved Changes

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Ireland

Irish Revenue has issued eBrief No. 085/25 concerning a new Tax and Duty Manual Part 33-02-03, providing guidance on the general anti-avoidance rule and protective notifications. --- 1. Introduction This manual provides guidance on the general anti-avoidance rule contained in section 811C1. It sets out the implications of entering into a ‘tax avoidance transaction’, within the meaning of section 811C, and what you can do if you enter into, or have entered into, a transaction that you are concerned may be a ‘tax avoidance transaction’. This manual also provides an outline of how interest and the tax avoidance surcharge can...