Financial Services Ireland

Tax Alert: Tax and Duty Manual “Section 110: entitlement to treatment” (May 2018)

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Tax Alert: Tax and Duty Manual “Section 110: entitlement to treatment” (May 2018)

On 24 May the Irish Revenue Commissioners (“Revenue”) published a Tax and Duty Manual entitled “Section 110: entitlement to treatment” (the “Manual”). The Manual is an important development for a number of reasons. We strongly recommend that those utilising Section 110 Taxes Consolidation Act 1997 (“Section 110”) consult with their tax advisers to consider the implications for their transactions.

Taxpayers should be aware that the Manual is indicative of Revenue’s ever increasing attention to Section 110 and their desire to ensure that it is not utilised for transactions which they would view as not genuinely satisfying the various conditions and anti-avoidance provisions. We would expect Revenue audit activity to focus on the points mentioned. It is also worth bearing in mind from a practical perspective that your auditors will likely focus more closely on the points of emphasis in the Manual.

This Alert summarises the key changes and important points of emphasis in the Manual.

Click on the box below to view the alert.

Thought Leaders


Aidan Walsh

International Banking, Sector Leader

Petrina Smyth

Associate Partner, Business Tax Advisory






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