Financing Transactions - Accessing Irish Corporation Tax Relief

Introduction

This webinar will cover the key legislative provisions contained in Sections 247 and 249 of the Taxes Consolidation Act 1997. These provisions govern the availability of corporation tax relief for interest paid on qualifying borrowings drawn down (from both internal and external sources) to acquire shares in or to lend to other companies in the Republic of Ireland.

This is a valuable measure, providing full corporation tax relief for interest paid on qualifying borrowings and significant care is required in structuring transactions to secure the interest relief.

This webinar will be of interest to anybody advising companies in Ireland on structuring and executing transactions involving the drawdown of borrowings for the purpose of acquiring shares in or lending to other companies where Irish corporation tax relief will be sought for the interest paid.

What You Will Learn

This webinar will cover the following:

• The types of transactions which qualify for interest relief
• The conditions which must be satisfied when the borrowings are drawn down and when the interest is paid
• Issues commonly encountered in satisfying the conditions for interest relief
• The changes made in Finance Act 2017 to legislate for multiple holding company structures and some practical difficulties presented by the changes
• The wide scope of the 'recovery of capital' provisions and common transactions which can give rise to an interest restriction for the borrower
• How interest relief may be utilised by the borrower / by other group members by way of group relief

This webinar was recorded on 18th July 2018