Revenue has updated the Tax and Duty Manual which sets out
guidelines for determining the residence of trusts and estates under administration in accordance with the Double Tax Treaty between Ireland the United Kingdom. The manual 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.
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