As many members will know, HM Revenue & Customs (HMRC) has had a foreign-entity classification list for UK tax purposes for a number of years, which has provided relative certainty on how the UK views certain entities. For example, the UK guidance notes that Irish limited partnerships, Irish investment limited partnerships and common contractual funds will be viewed as transparent for UK tax purposes.[1] Many Irish practitioners and taxpayers had been hoping for a number of years for Revenue to take a similar approach to that of HMRC, and guidance on this topic was published for the first time in May 2023.
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