Clarification on Connected Person Rule for Relevant Contracts Tax
Revenue have issued eBrief No. 38/13 to confirm that the connected person rule per section 531 (1)(c) TCA 1997 will not apply where the only connected parties carrying on relevant operations are non-resident and are not carrying on a trade or business in the State through a branch or agency. Revenue’s Tax Manual at Part 18.02.02 has been updated to reflect this position. Revenue eBrief No. 38/13 is published in full here.