Finance Act 2025

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Taxation of certain foreign body corporates

36. Part 43 of the Principal Act is amended by the insertion of the following section after section 1009:

“1009A. Notwithstanding any provision of the Tax Acts or the Capital Gains Tax Acts, as the case may be, a body corporate and each of its members shall be chargeable to tax or capital gains tax, as the case may be, on their respective income, profits or gains on the basis that the body corporate is a partnership and each of its members are partners in a partnership where—

(a) the body corporate is incorporated, or formed, under the laws of a jurisdiction other than the State, and

(b) having regard to the characteristics of that body corporate and the rights and obligations of each of its members, the body corporate is substantially similar to a partnership formed under the law of the State.”.