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Finance Bill 2021 (‘the Bill’) introduced a new interest limitation rule (‘ILR’) as required by the EU’s anti-tax avoidance directive (‘ATAD’). This will have implications for taxpayers which have interest expenses in excess of interest income (known as ‘exceeding borrowing costs’).
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Every entity with significant interest expenses should carry out detailed modelling to understand the impact of these ILR rules on their future tax liabilities. The ILR will have a significant impact on certain financial services industries and how they can structure their funding without incurring a restriction on interest deductibility.
What are the implications for the structured finance industry?
The ILR have the potential to have a significant impact on s.110 companies who are typically debt financed. Where interest expenses exceeds interest income, this may result in some limitation on interest deductions.
Positively, gains/losses on debts are included in the definition of interest equivalent, but only where “reasonable to consider such amounts are economically equivalent to interest”. S.110 companies will need to determine what element of this income/expense would be reasonable to consider interest equivalent.
Where certain types of income are not deemed to be interest or an interest equivalent, this may result in an unexpected mismatch and a resultant restriction on interest deductibility.
What are the implications for the aviation finance industry?
A positive development for the aviation finance industry is the inclusion of the finance component of lease rentals in the definition of interest equivalent for entities carrying on a leasing trade.
However, determining the elements of lease compensation payments and maintenance events is complex and will need detailed consideration and modelling.
Aviation finance entities will now need to look at their finance and operating leases separately and determine the components of income and expenses equivalent to interest.
Other points to note
The Single Company Worldwide Group provision may be helpful for orphan s.110 entities, allowing access to the group ratio to such entities even though they are not members of a worldwide group.
Where the S.110 taxable income is calculated under 2004 Old Irish GAAP, these accounts should be used for the purposes of the calculations under the ILR, as opposed to the statutory accounts.
The interest group detailed above could include an Irish QIAIF (Qualifying Investor Alternative Investment Fund) established as a corporate (e.g. an ICAV) which may be useful in a s.110 / QIAIF structure.
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The next stage of the process at which amendments may be made is the Committee Stage followed by the Report Stage and the Seanad. It is unclear if any significant amendments will be made at these stages. The ILR are expected to be signed into law in December, and will come into effect for “accounting periods” commencing on or after 1 January 2022. This allows for more time for modelling for non-31 December year ends where applicable.
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For additional information on any of the foregoing provisions or assistance with modelling, please feel free to contact us.
