Revenue Note for Guidance

The content shown on this page is a Note for Guidance produced by the Irish Revenue Commissioners. To view the section of legislation to which the Note for Guidance applies, click the link below:

Revenue Note for Guidance

697O Capital allowances: general

(1) A company’s tonnage tax trade is not to be treated as a trade for the purposes of entitlement to capital allowances. The effect of this is that a company is not entitled to capital allowances in respect of capital expenditure on assets which are used in the company’s tonnage tax trade for the duration of their use in that trade. The provision makes it clear that a balancing charge may still be made on a tonnage tax company where appropriate.

(2) Individual lessors are prohibited from obtaining the capital allowances which would otherwise be available in respect of capital expenditure on plant or machinery used in a company’s tonnage tax trade.

(3) Part 3 of Schedule 18B is specifically applied for the purposes of giving effect to the capital allowances provisions in relation to a tonnage tax trade. Extensive adaptations of those provisions are contained in that Part of Schedule 18B.

Relevant Date: Finance Act 2021