Revenue eBrief No. 289/24
27 November 2024
Interest on loans to defray money applied for certain purposes
Revenue has published a new Tax and Duty Manual – Part 36-00-19 Interest on loans to defray money applied for certain purposes, providing guidance on section 840A TCA 1997.
Section 840A is an anti-avoidance provision which restricts the ability of certain companies (referred to as “investing companies” in the section) to claim a deduction for interest payable on certain connected party borrowings to fund the acquisition of certain assets from other group companies.