The consultation period closes on 16 January 2026.
Ireland’s Department of Finance has opened a consultation on Phase One of its proposed reform of the country’s interest taxation regime.
The consultation period begins on 21 November 2025.
The reform, outlined in a “Strawman Proposal,” aims to modernise Ireland’s interest tax rules and align them with international best practices. Key measures include a new “profit motive” test for interest deductibility under Corporation Tax, the adoption of an accruals basis for assessing all interest income, and adjustments to the Interest Limitation Rule’s de minimis threshold at a group level.
The proposals also seek to extend Transfer Pricing rules to medium-sized enterprises and to clarify the treatment of interest equivalents, while considering simplifying complex existing provisions, such as Section 247.
Stakeholders are invited to submit feedback via email to interestreview@finance.gov.ie or by post to the Business and International Tax Division, Department of Finance, Government Buildings, Dublin 2. Early engagement is encouraged, as submissions received after the deadline may not be considered.
The Department will review responses before finalising legislation for inclusion in the Finance Bill 2026.
The consultation period ends on 16 January 2026.
Earlier, the Department of Finance announced the initiation of a public consultation regarding the tax treatment of interest on 27 September 2024.
