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Statutory Codification Of Foreign Entity Tax Classification In Ireland
Ireland has introduced Section 1009A of the Taxes Consolidation Act 1997, marking the first time Irish legislation directly addresses the tax transparency of foreign entities. This groundbreaking provision has significant implications for cross-border investment structures involving Irish funds, particularly those utilizing Delaware limited partnerships, U.K. LLPs, and U.S. LLCs, with downstream consequences for Pillar 2 and anti-hybrid mismatch rules.
Maples Group