Revenue eBrief No. 291/24
27 November 2024
Transfer of close company status opinions under TDM 13-01-02 to Revenue Technical Service
Tax and Duty Manual (TDM) Part 13-01-02 has been updated. This TDM explains some of the key definitions and terms used in the close company provisions in Part 13 of the Taxes Consolidation Act 1997.
Paragraph 1 of the TDM outlines how taxpayers can seek agreement from Revenue that the close company legislation will not apply to an Irish resident company in certain circumstances, where the ultimate ownership and control of the company is widely dispersed among a large number of investors in funds operated through a limited partnership structure.
This paragraph has also been updated to reflect this change and outlines the details that must be submitted to Revenue in order for the request to be considered.
With effect from 2 December 2024, these requests must be submitted to Revenue via the Revenue Technical Service in accordance with the procedures set out in the Revenue Technical Service Guidelines (TDM Part 37-00-00a).