Revenue eBrief No. 169/21
06 September 2021
Section 110 companies
Tax and Duty Manual Part 04-09-01, which provides guidance on the tax treatment of qualifying companies under section 110, has been updated to provide:
- Clarifications in relation to Transfer Pricing rules
- Updates to reflect FA19 amendments in relation to the meaning of control, significant influence and the main purpose test
- Clarification with regard to disregarded entities and subject to tax condition.