Revenue eBrief No. 141/24
21 May 2024
Residence of Trusts (other than Unit Trusts) and of Estates under administration- Ireland and the United Kingdom
Tax and Duty Manual Part 34-00-02 has been updated to incorporate changes to Article 4(3) of the Double Tax Treaty between Ireland and the United Kingdom arising from the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).
The MLI introduced a new tie-breaker rule for the determination of treaty residence of persons, other than individuals, that are resident of more than one jurisdiction.