The significant downside of the rushed Finance Bill process this year was that awkward legislation did not receive adequate consideration before being signed into law. Revenue's eBrief No. 11/11 effectively introduces a “bona fide” test to draw the sting from Finance Act 2011 sections 36 and 37 as far as certain loans are concerned. These sections generally disallow interest relief on intra group borrowings except in the most limited of circumstances. The “bona fide” test may be a partial remedy against choking off real commercial arrangements. eBrief No. 11/11 is available here.