Revenue eBrief No. 227/25
03 December 2025
Guidance on the Interest Limitation Rule
Tax and Duty Manual Part 35D-01-01 - Guidance on the Interest Limitation Rule has been updated as follows:
- to update the guidance in relation to the association tests in Part 35D with respect to partnerships, drawing from the guidance in TDM 43-00-03 (Taxation of Partnerships) and in line with the recently updated guidance in TDM 35C-00-01 (Guidance on the Anti-Hybrid Rules), and
- to include an additional Appendix (Appendix 3) to provide further clarity on the population of the Form CT1 with regards to the interest limitation rules.