Revenue eBrief No. 141/19
22 July 2019
Controlled Foreign Companies
A new Tax and Duty Manual, Part 35b-01-01 has been published in respect of the Controlled Foreign Company (CFC) rules, that were introduced by Finance Act 2018 and take effect from 1 January 2019.
The manual provides an overview of what the CFC rules mean and how they operate. It sets out information in relation to what a CFC is, the meaning of ‘control’ and ‘associated companies’, how a CFC charge can arise and the relevant exemptions and reliefs.