Course description
This webinar will cover the key provisions 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.
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.
Presented by Stephen Ruane and Fiona Carney of PwC's Tax Solutions Centre, this handy 1 hour update is essential viewing for anybody advising companies 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.
Upcoming start dates
Outcome / Qualification etc.
Training Course Content
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
Expenses
MBL Seminars Limited
MBL is a leading learning and development provider for professional service firms. Over the past 18 years, more than 198,000 people across 23,000 different organisations spanning 81 countries, have chosen us to deliver their training. With over 800 expert speakers...