Interest on Loans - Company ceased

31/05/1996

Query

Individuals borrowed money which was applied in acquiring an interest in a company. The company subsequently ceased to trade. Can the individuals still claim relief under S 248 TCA 1997

Decision

Relief is not due. The company no longer existed for the purposes set out in the section. Separately, at the time the interest was paid, the individuals did not have a material interest in the company or a connected company

Income Tax

Section 248, Taxes Consolidation Act, 1997

Origin: RLS Division

File ref:IT 96 1560




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