The Interest Limitation Rule (ILR), which takes effect for accounting periods beginning on or after 1 January 2022, transposes into Irish tax legislation Article 4 of the EU Anti-Tax-Avoidance Directive (ATAD). In the previous two Issues of Irish Tax Review the key provisions of the ILR, including areas to watch and key issues for SMEs, were addressed. This article provides an overview of important areas of interpretation, including relevant Revenue guidance issued in August 2022 (Tax and Duty Manual Part 35D-01-01, “Guidance on the Interest Limitation Rule”).
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