Revenue eBrief No. 007/26
06 January 2026
Interest on loans to defray money applied for certain purposes
Tax and Duty Manual Part 36-00-19 - Interest on loans to defray money applied for certain purposes - contains guidance on section 840A Taxes Consolidation Act 1997. Section 840A is an anti-avoidance provision that denies a deduction for interest payable by a company on a loan from a connected person used to purchase an asset from a connected company, subject to certain exclusions.
The manual has been updated to reflect changes made to section 840A by Finance Act 2025. Specifically -
- Paragraph 5.2.1 ‘Sole business of lending’ has been updated to reflect changes made to subsection (7), and
- A new paragraph 5.3, including examples, in respect of the new subsection (7A) has been included.