Irish Revenue Issues New Guidance on
Territorial Scope of VAT Groups

Irish Revenue has published eBrief No. 216/25, introducing new and updated guidance on the territorial scope of VAT Groups. The guidance clarifies which entities can be included in an Irish VAT group, particularly in light of recent Court of Justice of the European Union (CJEU) rulings.

Key Change:

The guidance confirms that VAT grouping is only available to establishments located within Ireland. Consequently, non-Irish head offices or branches (even those in other EU Member States) cannot be members of an Irish VAT group.

This change means that supplies between these non-Irish establishments and an Irish VAT group are now definitively within the scope of VAT.

Implementation Date:

Existing VAT Groups that are impacted by this change must implement the new guidance by December 31, 2026.

https://www.revenue.ie/en/tax-professionals/ebrief/2025/no-2162025.aspx

The guidance takes immediate effect for any newly established VAT Groups.