On 12 June 2017, the Irish Revenue published updates to the Tax and Duty Manual Part 08-02-01 dealing with charges on income for Corporation Tax purposes. The principal updates are in relation to interest as a charge on income under section 247 Taxes Consolidation Act 1997. In particular, the revised manual contains information on the anti-avoidance provisions that apply in respect of section 247 and related exclusions.
The updated manual also addresses the availability of relief under section 247 where shares are acquired pursuant to a court-approved scheme of arrangement effected in accordance with Chapter 1 of Part 9 of the Companies Act 2014.
