747AA Treatment of certain offshore funds

This section provides for the treatment of offshore funds in the EU, the European Economic Area or in OECD countries with which Ireland has a double tax treaty that fall outside the scope of the gross roll up regime by virtue of section 747B(2A). Such funds do not qualify for offshore fund treatment of any sort. Instead, income and gains are taxed under general taxation principles. This is similar to the treatment of income and gains in the case of Irish entities that do not come within the scope of the domestic “gross roll up” regime.

Relevant Date: Finance Act 2019