Revenue eBrief No. 117/23

18 May 2023

Foreign Entity Classification for Irish Tax Purposes

Where a foreign entity is involved in a transaction the classification of that foreign entity can be central in determining any Irish tax implications. The purpose of Tax and Duty Manual (TDM) Part 35C-00-02 – Foreign Entity Classification For Irish Tax Purposes – is to provide clarity on the approach taken by Revenue when classifying a foreign entity for the purposes of Irish tax law.