Taxes Consolidation Act 1997 section 835AAL

Application of Part to interest group

Section 835AAL sets out how the interest limitation rules under Part 35D apply where a company is a member of an interest group, including how the disallowable amount and total spare capacity are calculated and allocated among group members.

• An interest group's disallowable amount is allocated to each member as a fraction based on the member's deductible interest equivalent relative to the group's deductible interest equivalent, but the reporting company and group members may jointly notify Revenue of an alternative allocation.
• Total spare capacity is similarly allocated as a fraction based on each member's taxable interest equivalent relative to the group's, with an option for alternative allocation by joint notification to Revenue.
• The interest group's accounting period is the period common to more than half of the members; where a member's accounting period does not coincide, its results are apportioned on a just and reasonable basis.
• The equity ratio for an interest group is calculated on a consolidated basis as if all members had a common Irish resident ultimate parent, using the same accounting standards as the worldwide group's consolidated financial statements.