Revenue eBrief No. 166/22
07 September 2022
Attribution of profits to a branch
Section 28 of Finance Act 2021 inserted a new section 25A into the Taxes Consolidation Act 1997 to provide for the application of an OECD-developed mechanism (the “authorised OECD approach” or “AOA”) for the attribution of income to a branch or agency of a non-resident company operating in the State.
The new section 25A applies for accounting periods commencing on or after 1 January 2022.
Tax and Duty Manual (TDM) Part 02-02-04a provides an overview of, and guidance in relation to, the legislation contained within section 25A.