Revenue Announce Change to Territorial Scope of VAT Groups

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Revenue has published eBrief No. 216/25 confirming significant changes to its interpretation of VAT grouping rules in Ireland.

What’s Changed?

  • VAT grouping is now limited to Irish establishments only – a head office or branch located in Ireland.
  • Non-Irish head offices or branches of VAT group members are no longer considered part of the Irish VAT group.
  • This new guidance applies immediately to VAT groups established from the date of publication (19 November 2025).
  • Existing VAT groups have a transitional period until 31 December 2026 to comply.

Previous Position

Revenue previously treated the entire legal entity (including overseas branches) as part of the Irish VAT group. This interpretation has now changed.

Impact

From 1 January 2027, transactions between Irish VAT group members and their overseas branches will generally fall within the scope of Irish VAT.

Next Steps

Revenue advises:
“Those existing VAT Groups impacted by this change can contact their Revenue District to agree suitable transitional arrangements to ensure compliance with this guidance.”

If you have any queries, please contact us.

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