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Irish Revenue Updates Guidance on Anti-Hybrid Rules

20 December 2024

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Approved Changes

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Ireland

Irish Revenue has issued eBrief No. 303/24 on updated guidance on anti-hybrid rules. --- Revenue eBrief No. 303/24 Guidance on Anti-Hybrid Rules Tax and Duty Manual Part 35C-00-01 Part 35C-00-01 has been updated as follows: Section 1: Introduction to hybrid mismatches, to clarify that OECD guidance on hybrid mismatches cannot be relied upon to disapply the hybrid mismatch rules in ATAD2, as transposed into Part 35C. Section 2: Mismatch outcomes, updated to introduce the concept of primary and defensive anti-hybrid rules. Section 3: Interpretation (Section 853Z), updated to include definitions of 'deduction' and 'structured arrangement'. Section 4.2.1 Section 835Z(1)(a), updated...