Irish Revenue has issued eBrief No. 099/24 concerning updates to the Tax and Duty Manual on Controlled Foreign Company (CFC) Rules (Part 35b-01-01) to reflect amendments introduced by Finance (No. 2) Act 2023. In particular, updates have been made to Chapter 11 on the defensive measures targeted at jurisdictions listed by the EU as non-cooperative. The defensive measures disapply the effective tax rate exemption, the low profit margin exemption, and the low accounting profit exemption so that an Irish resident company with a CFC resident in a listed jurisdiction may not avail of these exemptions. In this respect, Chapter 11...