Irish Revenue has issued eBrief No. 023/25 concerning updates to the Tax and Duty Manual (TDM) on Controlled Foreign Company (CFC) Rules (Part 35b-01-01). This includes updates to Chapter 11 of the TDM resulting from the Finance Act 2024 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. The 2024 list, as updated in October 2024,...