Revenue eBrief No. 058/19

19 March 2019

Charges on income for Corporation Tax purposes

Tax and Duty Manual Part 08-02-01 has been updated to reflect Finance Act 2017 amendments to section 247 of the Taxes Consolidation Act 1997 (Charges on income for Corporation Tax purposes). 

Section 247 has been amended to allow relief for interest on a loan used to acquire, or in certain circumstances lend to, a holding company that indirectly holds shares in a trading company through one or more intermediate holding companies.

The amendments put into legislation an administrative practice that was operated by Revenue.