Revenue eBrief No. 198/22
21 November 2022
Accelerated loss relief for companies adversely impacted by the Covid-19 pandemic restrictions
Section 11 of the Financial Provisions (Covid-19) (No. 2) Act 2020 introduced a new section 396D in the Taxes Consolidation Act 1997 ("TCA"). Section 396D TCA provided for a temporary acceleration of corporation tax loss relief for accounting periods affected by the Covid-19 pandemic and related restrictions.
Tax and Duty Manual Part 12-03-05, which provides guidance on section 396D, has been updated:
- in both the introduction and section 2.7, to outline that accelerated loss relief under section 396D is no longer available due to the time limits provided for in the legislation. The last possible date by which a claim could be made under section 396D was 30 May 2022, and
- to include references to section 1077F and the new Code of Practice for Revenue Compliance Interventions.