Revenue eBrief No. 062/20
14 April 2020
Treatment of Additional Tier 1 Capital – section 845C, Taxes Consolidation Act, 1997
A new Tax and Duty Manual (TDM), Part 36-00-18 - Treatment of Additional Tier 1 Capital, has been published in respect of section 845C, which was amended by Finance Act 2019.
The TDM outlines how section 845C provides clarity on the tax treatment of Additional Tier 1 instruments and, following the Finance Act 2019 amendment, other
equivalent instruments that are not issued by financial institutions. It details the approach a taxpayer should take when determining what an Additional Tier 1-equivalent instrument is.