On 12 June 2017, Irish Revenue issued eBrief No. 64/17 announcing the publication of Revenue Tax and Duty Manual Part 02-02-03a, which deals with the tax treatment of foreign dividends paid out of trading profits, which may be chargeable to corporation tax at the standard rate of 12.5% (trading income rate) rather than at 25% (passive income rate). The manual sets out:

• The nature of dividends…