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Irish Revenue Guidance on Anti-Avoidance Provision to Restrict Interest Deductions on Connected Person Loans to Acquire Connected Company Assets

03 December 2024

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Approved Changes

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Ireland

Irish Revenue has issued eBrief No. 289/24 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 of the Taxes Consolidation Act 1997 (TCA), which restricts the deduction of interest on loans from a connected person for the acquisition of assets from a connected company. The guidance covers the general rules of the restriction as well as certain exclusions. --- 1 Introduction Section 840A restricts the ability of certain companies (referred to as "investing companies" in this section) to claim a deduction for interest payable on...