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Commentary

IR2.10.3 New Interest Limitation Rules (ILR)

Republic of Ireland

Finance Act 2021 introduced new ILR provisions into Irish tax law.

These provisions are significant for businesses that use inter-group treasury/ lending arrangements and come within the realm of the measures. The effect of the ILR is to place a limit on deductible interest costs of 30% of EBITDA for companies that come within its scope. The default rate of the fixed ratio is set at 30% however, in certain circumstances a taxpayer may deduct an amount in excess of 30% of tax-adjusted EBITDA under

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