Irish Revenue has issued eBrief No. 156/22, announcing a new Tax and Duty Manual (TDM) Part 35D-01-01 on the interest limitation rule introduced as part of the Finance Act 2021. The new rule, which is in line with the EU Anti-Tax Avoidance Directive (ATAD), limits deductible interest expense to 30% of EBITDA, with disallowed interest allowed to be carried forward and deducted in future years.
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Introduction
Council Directive (EU) 2016/1164 of 12 July 2016, as amended by Council Direc…