Revenue eBrief No. 071/21

31 March 2021

Tax and Duty Manual Part 09-02-05 - Capital allowances for intangible assets - updated

Revenue Tax and Duty Manual Part 09-02-05 - Capital Allowances for Intangible Assets - provides guidance on the operation of section 291A of the Taxes Consolidation Act 1997 (“TCA 1997”), which makes provision for capital allowances for expenditure incurred by companies on intangible assets. 

The following sections in the manual have been updated to reflect a Finance Act 2020 amendment to section 288(3C):

  • 2. Overview of scheme – fourth paragraph
  • 3.11 Will a balancing charge or balancing allowance apply on the disposal of an intangible asset?

In addition to the above, the following new sections have been added to the manual:

  • 3.14 Where section 400 applies to a company reconstruction, are allowances available to the successor under section 291A?
  • 3.15 How does section 291A interact with the transfer pricing rules in Part 35A?