On 6 August 2020, the Revenue published an eBrief 150/20 regarding loss relief for COVID-19 affected companies. A new Tax and Duty Manual has been published to provide guidance on the operation of section 396D TCA, as well as to provide information to companies on how they may make a claim for the relief.
Section 11 of the Financial Provisions (Covid-19) (No. 2) Act 2020 introduced a new section 396D in the Taxes Consolidation Act 1997 (“TCA”). Section 396D TCA provides for a temporary acceleration of corporation tax loss relief for accounting periods affected by the Covid-19 pandemic and related restrictions. It allows companies to estimate their trading losses for certain accounting periods and to carry back up to 50% of those losses against chargeable profits of the preceding accounting period on an accelerated basis.