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

|Approved Changes|Ireland
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.

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1 Introduction

Section 840A restricts the…

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