Revenue has revised two of its close company guidance notes by reorganising the material and including additional information and examples illustrating how the provisions operate. The relevant manuals relate to certain settlements made by close companies and treatment of interest payments and other forms of consideration as distributions.
The guidance on certain settlements made by close companies relates to the provisions of section 436A TCA 1997 and the transfer of funds from close companies through the use of trusts and other arrangements.
The guidance on the tax treatment of certain payments made by close companies to participators and directors under sections 436 and 437 TCA 1997 outlines how these provisions classify interest payments that exceed specified limits, as well as expenses incurred in providing certain benefits, as distributions.