Interest paid
31/12/1990
Query
Whether the reference in section 496(4) ITA 1967to money used to pay death duties included a reference to money used to pay inheritance tax
Decision
No
Income Tax
Section 496, Income Tax Act, 1967
Origin: RLS Division
File ref:IT902039
03/03/1992
Query
Whether obligation to deduct and account for tax applies where payment is made from taxed profits
Decision
Yes; section 246 treats a payment of interest as one to which section 238 TCA applies i.e. the payment is treated as made out of profits or gains not brought into charge to tax
Income Tax
Section 246, Taxes Consolidation Act, 1997
Origin: RLS Division
File ref:922017
10/08/1993
Query
Whether interest paid on a loan used to repay a loan for which relief allowable under section 97 would be allowed under section 97
Decision
Yes; provided the redemption of the earlier loan was for bona fide commercial reasons and not for the avoidance of tax, the interest could be allowed in computing profit rent.
Income Tax
Section 97, Taxes Consolidation Act, 1997
Origin: RLS Division
File ref:IT932019
11/10/1993
Query
Whether interest on money advance to company allowable, where the company had been struck off the comapnies register
Decision
No; if the company was restored to the register, interest would be allowed for the periods during which it was struck off
Income Tax
Section 248, Taxes Consolidation Act, 1997
Origin: RLS Division
File ref:IT932018