Chartered Accountants Ireland, under the auspices of the CCAB-I, responded to the Department of Finance’s consultation on the implementation of an ‘interest limitation rule’ (ILR) into Irish law. An Irish ILR is expected to be introduced in Finance Act 2021 as required by the EU Anti-Tax Avoidance Directive (Council Directive 2016/1164) (“ATAD”). The ILR will restrict tax-deductible interest of an entity to 30 percent of its earnings before interest, tax, depreciation, and amortisation (“EBITDA”) in a tax period. The CCAB-I’s submission calls for current interest restriction measures to be re-evaluated and reduced on the introduction of an ATAD compliant interest limitation rule.

The CCAB-I’s submission supports the Department of Finance’s approach of extensive consultation in drafting ILR measures for Finance Act 2021. The CCAB-I also wrote to the Minister for Finance, Paschal Donohoe, endorsing the Minister’s plans for extensive stakeholder consultation as set out in the updated Corporation Tax Roadmap.