Revenue eBrief No. 014/26
16 January 2026
Treatment of certain payments by a close company as distributions
Tax and Duty Manual Part 13-02-01 contains guidance on the tax treatment of certain payments by close companies to participators and directors under sections 436 and 437 TCA 1997. These provisions treat interest payments exceeding a prescribed limit and expenses incurred in providing certain benefits as distributions.
The guidance has been updated to restructure the content and to provide additional information and examples on the operation of these provisions.