Irish Tax and Customs has updated its Tax and Duty Manual to account for Finance Act 2019 changes regarding the dividend withholding tax, to clarify the law around tax statutes that employ a “main purpose test,” and to clarify the mandatory disclosure regime.
The manual was updated on February 3 to reflect an increase in the rate of the dividend withholding tax to 25%, the government said. The updates also reflect the requirement that from January 1, 2021, a company or intermediary that pays the relevant distribution shall obtain and keep a record of the “tax reference number” of the person or persons beneficially entitled to the relevant distribution. The manual makes a minor change to update the reference to the rate of interest for overdue dividend withholding tax.
On February 4 Part 33-01-01 of the manual was updated to summarize the case law concerning the “main purpose test” used in anti-avoidance sections, Irish Revenue said. Further, the manual was updated to include a reference to the EU mandatory disclosure regime, effective in Ireland on July 1, 2020, and includes a “main benefit test.” The new mandatory disclosure regime includes a “lookback” reporting requirement, Irish Revenue noted, which will apply to reportable cross-border arrangements.
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