Irish Revenue has issued eBrief No. 189/23 concerning updates to Tax and Duty Manual Part 12-03-04 – Company Reconstructions without change of ownership. The updates reflect amendments made to section 400 TCA 1997 as a result of the introduction of the Interest Limitation Rules in Part 35D in Finance Act 2021. In particular, the update concerns the carry-over of relief for deemed borrowing costs or total spare capacity under the Interest Limitation Rules from one company to another in cases where a company ceases to carry on a trade and another company begins to carry on the trade, subject to...