Section 247 of the Taxes Consolidation Act allows Corporation Tax (CT) relief for interest on certain loans. These loans are used to either obtain an interest in, or lend to, Irish trading or rental companies.
To qualify, the borrowing company must hold a minimum of 5% shareholding in the other company. They must not recover capital within two years before the loan is applied. Both companies must have at least one common director.
From 21 January 2011, there are certain restrictions on relief under Section 247. See Part 8 Chapter 3 of the Notes for Guidance - Taxes Consolidation Act 1997 (Finance Act 2022 Edition) for details of these restrictions.