Global Daily Tax News, Ireland Clarifies Interest Deduction Relief For QFCs, (Nov 18, 2024)

The Irish Revenue has released a new Tax And Duty Manual, Part 04-05-07, to provide guidance on the deductibility of interest by intermediary financing companies under section 76E.

The relief was introduced in Finance (No. 2) Act 2023. It permits certain intermediary financing companies, known as Qualifying Financing Companies (or QFCs), to obtain a deduction for interest paid on certain external/third party loans.

The guidance explains eligibility conditions as well as calculation issues, including in relation to shareholder debt, refinancings, replacement loans, external refinancings, and repayments and deemed repayments to QFCs.

The guidance concludes by discussing anti-avoidance provisions.