Irish Revenue has issued eBrief No. 119/24 on the revision of several Tax and Duty Manuals considering the new outbound payments defensive measures introduced as part of the Finance (No.2) Act 2023. As previously reported, the new defensive measures apply with regard to outbound payments of interest, royalties, and distributions (including dividends) to associated entities resident in jurisdictions on the EU list of non-cooperative jurisdictions, as well as no-tax and zero-tax jurisdictions. The measures are meant to ensure the prevention of double non-taxation and essentially restrict domestic withholding tax exemptions in respect of captured payments and require the reporting of...