Revenue eBrief No. 216/22

21 December 2022

Section 110: Entitlement to Treatment

Tax and Duty Manual Part 04-09-01, which provides guidance on Section 110 of the Taxes Consolidation Act 1997, has been updated to provide clarification on:

• the “double trade” test and
• the deductibility of payments to the European Bank for Reconstruction and Development.