Taxes Consolidation Act, 1997 (Number 39 of 1997)
97 Computational rules and allowable deductions.
[ITA67 s81(4), (5), (6), (7) and (8); FA69 s22; FA97 s146(1) and Sch9 PtI par1(6)]
(1) Subject to this Chapter, the amount of the profits or gains arising in any year shall for the purposes of Case V of Schedule D be computed as follows:
(a) the amount of any rent shall be taken to be the gross amount of that rent before any deduction for income tax;
(b) the amount of the profits or gains arising in any year shall be the aggregate of the surpluses computed in accordance with paragraph (c), reduced by the aggregate of the deficiencies as so computed;
(c) the amount of the surplus or deficiency in respect of each rent or in respect of the total receipts from easements shall be computed by making the deductions authorised by subsection (2) from the rent or total receipts from easements, as the case may be, to which the person chargeable becomes entitled in any year.
(2) The deductions authorised by this subsection shall be deductions by reference to any or all of the following matters—
(a) the amount of any rent payable by the person chargeable in respect of the premises or in respect of a part of the premises;
(b) any sums borne by the person chargeable—
(i) in the case of a rent under a lease, in accordance with the conditions of the lease, and
(ii) in any other case, relating to and constituting an expense of the transaction or transactions under which the rents or receipts were received,
in respect of any rate levied by a local authority, whether such sums are by law chargeable on such person or on some other person;
(c) the cost to the person chargeable of any services rendered or goods provided by such person, otherwise than as maintenance or repairs, being services or goods which—
(i) in the case of a rent under a lease, such person is legally bound under the lease to render or provide but in respect of which such person receives no separate consideration, and
(ii) in any other case, relate to and constitute an expense of the transaction or transactions under which the rents or receipts were received, not being an expense of a capital nature;
(d) the cost of maintenance, repairs, insurance and management of the premises borne by the person chargeable and relating to and constituting an expense of the transaction or transactions under which the rents or receipts were received, not being an expense of a capital nature;
(e) interest on borrowed money employed in the purchase, improvement or repair of the premises.
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(2A) Notwithstanding subsection (2) but subject to the other provisions of this section, a deduction shall not be authorised by paragraph (e) of that subsection by reference to interest on borrowed money employed on or after the 23rd day of April, 1998, in the purchase, improvement or repair of a premises which, at any time during the year, is a residential premises.
(2B) Subject to subsection (2C), subsection (2A) shall not apply in relation to interest on borrowed money employed—
(a) on or before the [2]>31st day of December, 1998<[2][2]>31st day of March, 1999<[2], in the purchase of a residential premises in pursuance of a contract which was evidenced in writing prior to the 23rd day of April, 1998, for the purchase of that premises,
(b) in the improvement or repair of a premises which on the 23rd day of April, 1998, or at any time during the 12 month period ending on that day, is or was a rented residential premises—
(i) in which the person chargeable had an estate or interest on that day, or
(ii) in respect of which the person chargeable is, or would be, entitled, by virtue of paragraph (a), to a deduction authorised by subsection (2)(e) by reference to interest on borrowed money employed in its purchase,
(c) in the purchase, improvement or repair of premises which is—
(i) a building or structure to which section 352 applies by virtue of the building or structure being a holiday cottage of the type referred to in section 268(3), or
(ii) a building or structure which is a qualifying premises within the meaning of section 353 by virtue of the building or structure being—
(I) a holiday apartment registered under Part III of the Tourist Traffic Act, 1939, or
(II) other self-catering accommodation specified in a list published under section 9 of the Tourist Traffic Act, 1957,
or
(iii) a qualifying premises within the meaning of section 356, 357 or 358,
(d) in the purchase, improvement or repair of any premises, other than premises to which paragraph (c) applies, the site of which is wholly within a qualifying rural area within the meaning of Chapter 8 of Part 10 of the Taxes Consolidation Act, [3]>1997, or<[3][3]>1997,<[3]
(e) in the purchase, improvement or repair of premises, other than premises to which paragraphs (c) and (d) apply, where—
(i) the premises is a holiday cottage, holiday apartment or other self-catering accommodation either registered under Part III of the Tourist Traffic Act, 1939, or specified in a list published under section 9 of the Tourist Traffic Act, 1957,
(ii) an application for planning permission for the development of the premises was received by a planning authority before the 23rd day of April, 1998, and
(iii) the terms under which planning permission in respect of the development of the premises was granted by the planning authority contain the condition that the premises may not be used by any person for residential use in excess of 2 consecutive calendar months at any one time and such condition is in force [4]>during the year.<[4][4]>during the year, or<[4]
[5]>
(f) in the purchase, improvement or repair of a premises which complies with the conditions of subsection (2F).
<[5]
(2C) (a) For the purposes of subsections (2A) and (2B), borrowed money employed on or after the 23rd day of April, 1998, on the construction of a building or part of a building for use or suitable for use as a dwelling on land in which the person chargeable has an estate or interest shall, together with any borrowed money which that person employed in the acquisition of such land, be deemed to be borrowed money employed in the purchase of a residential premises.
(b) In any case where paragraph (a) applies, subsection (2B)(a) shall apply only where the money is employed on or before the [2]>31st day of December, 1998<[2][2]>31st day of March, 1999<[2] and the person chargeable—
(i) has before the 23rd day of April, 1998, either—
(I) an estate or interest in land, or
(II) entered into a contract evidenced in writing to acquire an estate or interest in land,
and
(ii) in respect of any building or part of any building for use or suitable for use as a dwelling to be contructed on that land, either—
(I) has entered into a contract evidenced in writing before the 23rd day of April, 1998, for the construction of that building or that part of that building, or
(II) if no such contract exists, satisfies the Revenue Commissioners that the foundation for that building or that part of that building was laid in its entirety before the 23rd day of April, 1998.
(2D) Where—
(a) any premises in respect of which the person chargeable is entitled to a rent or to receipts from any easement consists in part of residential premises and in part of premises which are not residential premises, and
(b) subsection (2A) applies,
then, the amount of the deduction which is authorised under subsection (2)(e) by reference to interest on borrowed money employed in the purchase, improvement or repair of those premises shall be the amount of interest on that part of the borrowed money which can, on a just and reasonable basis, be attributed to that part of the premises which are not residential premises.
(2E) Notwithstanding anything contained in this section, where a premises in respect of which the person chargeable is entitled to a rent or to receipts from any easement is at any time on or after the 23rd day of April, 1998, the sole or main residence of that person, a deduction shall not be authorised by subsection (2)(e) by reference to any interest payable for any year or part of a year commencing after the date on which the premises ceases to be the sole or main residence of that person.
<[1]
[6]>
(2F) (a) The conditions of this subsection are—
(i) the premises was converted into multiple residential units prior to 1 October 1964,
(ii) the premises was acquired by the chargeable person under a contract which was evidenced in writing on or after 5 January 2001,
(iii) subsequent to the acquisition by the chargeable person of the premises, the number of residential units is not, subject to subparagraph (iv), reduced to less than 50 per cent of the total number of residential units contained in the premises at date of acquisition,
(iv) the premises consists throughout the year of a minimum of 3 residential units,
(v) at all times during the year (except for reasonable periods of temporary disuse between the ending of one lease and the commencement of another lease) not less than 50 per cent of the residential units in the premises are let under a lease where the lessee in the case of each such letting is either—
(I) a local authority, or a person nominated by a local authority under an agreement in writing between the lessor and that local authority, or
(II) a person who, at the commencement of the tenancy, is entitled to a payment under [11]>section 179 of the Social Welfare (Consolidation) Act, 1993,<[11][11]>section 198 of the Social Welfare Consolidation Act 2005,<[11] in respect of rent,
and
(vi) all the requirements of the following Regulations—
(I) the Housing (Standards for Rented Houses) Regulations, 1993 (S.I. No. 147 of 1993),
(II) the Housing (Rent Books) Regulations, 1993 (S.I. No. 146 of 1993), and
(III) the Housing (Registration of Rented Houses) Regulations, 1996 (S.I. No. 30 of 1996), as amended by the Housing (Registration of Rented Houses) (Amendment) Regulations, 2000 (S.I. No. 12 of 2000),
are complied with in relation to the premises throughout the year,
and
(b) in this subsection—
“local authority”, in relation to a premises, means the council of a county or the corporation of a county or other borough or, where appropriate, the council of an urban district in whose functional area the premises is located;
“residential unit” means a separately contained part of a residential premises used or suitable for use as a dwelling.
<[6]
[7]>
(2G) Subsections (2A) to (2F) shall not apply or have effect in relation to interest on borrowed money employed [8]>in the purchase<[8][8]>in the purchase, other than from the [13]>spouse<[13][13]>spouse or civil partner<[13] of the person chargeable<[8], improvement or repair of residential premises where that interest accrues on or after 1 January 2002 and, for the purposes of this subsection, interest on such borrowed money shall be treated as accruing from day to day.
<[7]
[14]>
[9]>
(2H) The reference to “spouse” in subsection (2G) does not include a spouse to a marriage—
(a) in which the spouses are separated under an order of a court of competent jurisdiction or by deed of separation, or
(b) that has been dissolved under either—
(i) section 5 of the Family Law (Divorce) Act 1996, or
(ii) the law of a country or jurisdiction other than the State, being a divorce that is entitled to be recognised as valid in the State.
<[9]
<[14]
[14]>
(2H) The reference to ‘spouse or civil partner’ in subsection (2G) does not include—
(a) a spouse to a marriage—
(i) in which the spouses are separated under an order of a court of competent jurisdiction or by deed of separation, or
(ii) that has been dissolved under either—
(I) section 5 of the Family Law (Divorce) Act 1996, or
(II) the law of a country or jurisdiction other than the State, being a divorce that is entitled to be recognised as valid in the State,
or
[15]>
(b) a civil partner in a civil partnership that has been dissolved under section 110 of the Civil Partnership and Certain Rights and Obligations of Cohabitants Act 2010 or deemed to have been so dissolved under section 5(4) of that Act.
<[15]
<[14]
[15]>
(b) a civil partner in a civil partnership—
(i) in which the civil partners are separated by a deed of separation, agreement, arrangement or any other act giving rise to a legally enforceable obligation and made or done in consideration or in consequence of living separately in the circumstances referred to in section 1031A(2), or
(ii) that has been dissolved under section 110 of the Civil Partnership and Certain Rights and Obligations of Cohabitants Act 2010 or deemed to have been so dissolved under section 5(4) of that Act.
<[15]
[10]>
(2I) (a) Notwithstanding subsection (2), a deduction shall not be authorised by paragraph (e) of that subsection by reference to interest payable for a chargeable period (within the meaning of section 321) on borrowed money employed in the purchase, improvement or repair of a rented residential premises unless the person chargeable can show that the registration requirements of Part 7 of the Residential Tenancies Act 2004 have been complied with in respect of all tenancies which existed in relation to that premises in that chargeable period.
(b) For the purposes of paragraph (a), a written communication from the Private Residential Tenancies Board to the chargeable person confirming the registration of a tenancy, relating to a rented residential premises to which paragraph (a) applies, shall be accepted as evidence that the registration requirement in respect of that tenancy (and that tenancy only) has been complied with.
<[10]
[17]>
[12]>
(2J) (a) Notwithstanding subsection (2) but subject to the other provisions of this section (including paragraph (b) of this subsection), the deduction authorised by subsection (2)(e) shall not exceed 75 per cent of the deduction that would, but for this subsection, be authorised by subsection (2)(e) in respect of interest accrued on or after 7 April 2009 on borrowed money employed in the purchase, improvement or repair of a premises which, at the time the interest accrues, is a residential premises and, for the purposes of this subsection, interest on such borrowed money shall be treated as accruing from day to day.
(b) For the purposes of paragraph (a)—
(i) borrowed money employed on the construction of a residential premises on land in which the person chargeable has an estate or interest shall, together with any borrowed money which that person employed in the acquisition of such land, be deemed to be borrowed money employed in the purchase of a residential premises, and
(ii) where a premises consists in part of residential premises and in part of premises which are not residential premises, paragraph (a) shall apply to the interest accrued on the part of the borrowed money employed in the purchase, improvement or repair of the premises that is attributable, on a just and reasonable basis, to residential premises.
<[12]
<[17]
[18]>
[17]>
(2J)(a)Notwithstanding subsection (2), but subject to the other provisions of this section (including paragraphs (b) and (c) of this subsection), the deduction authorised by subsection (2)(e) shall not exceed—
(i)75 per cent of the deduction that would, but for this subsection, be authorised by subsection (2)(e) in respect of interest accrued on or after 7 April 2009 up to and including 31 December 2016,
(ii)80 per cent of the deduction that would, but for this subsection, be authorised by subsection (2)(e) in respect of interest accrued on or after 1 January 2017 up to and including 31 December 2017,
(iii)85 per cent of the deduction that would, but for this subsection, be authorised by subsection (2)(e) in respect of interest accrued on or after 1 January 2018 up to and including 31 December 2018,
(iv)90 per cent of the deduction that would, but for this subsection, be authorised by subsection (2)(e) in respect of interest accrued on or after 1 January 2019 up to and including 31 December 2019, and
(v) 95 per cent of the deduction that would, but for this subsection, be authorised by subsection (2)(e) in respect of interest accrued on or after 1 January 2020 up to and including 31 December 2020,
on borrowed money employed in the purchase, improvement or repair of a premises which, at the time the interest accrues, is a residential premises.
(b)For the purposes of paragraph (a)—
(i)borrowed money employed on the construction of a residential premises on land in which the person chargeable has an estate or interest shall, together with any borrowed money which that person employed in the acquisition of such land, be deemed to be borrowed money employed in the purchase of a residential premises,
(ii)where a premises consists in part of residential premises and in part of premises which are not residential premises, paragraph (a) shall apply to the interest accrued on the part of the borrowed money employed in the purchase, improvement or repair of the premises that is attributable, on a just and reasonable basis, to residential premises, and
(iii)the interest on borrowed money referred to in paragraph (a) shall be treated as accruing from day to day.
(c)This subsection shall not apply in respect of interest accrued on or after 1 January 2021.
<[17]
<[18]
[18]>
(2J) (a) Notwithstanding subsection (2), but subject to the other provisions of this section (including paragraphs (b) and (c) of this subsection), the deduction authorised by subsection (2)(e) shall not exceed—
(i) 75 per cent of the deduction that would, but for this subsection, be authorised by subsection (2)(e) in respect of interest accrued on or after 7 April 2009 up to and including 31 December 2016,
(ii) 80 per cent of the deduction that would, but for this subsection, be authorised by subsection (2)(e) in respect of interest accrued on or after 1 January 2017 up to and including 31 December 2017, and
(iii) 85 per cent of the deduction that would, but for this subsection, be authorised by subsection (2)(e) in respect of interest accrued on or after 1 January 2018 up to and including 31 December 2018,
on borrowed money employed in the purchase, improvement or repair of a premises which, at the time the interest accrues, is a residential premises.
(b) For the purposes of paragraph (a)—
(i) borrowed money employed on the construction of a residential premises on land in which the person chargeable has an estate or interest shall, together with any borrowed money which that person employed in the acquisition of such land, be deemed to be borrowed money employed in the purchase of a residential premises,
(ii) where a premises consists in part of residential premises and in part of premises which are not residential premises, paragraph (a) shall apply to the interest accrued on the part of the borrowed money employed in the purchase, improvement or repair of the premises that is attributable, on a just and reasonable basis, to residential premises, and
(iii) the interest on borrowed money referred to in paragraph (a) shall be treated as accruing from day to day.
(c) This subsection shall not apply in respect of interest accrued on or after 1 January 2019.
<[18]
[16]>
(2K) (a) In this subsection—
“Board” means the Private Residential Tenancies Board;
“household” has the meaning assigned by the Housing (Miscellaneous Provisions) Act 2009;
“housing authority” has the meaning assigned by the Housing (Miscellaneous Provisions) Act 1992;
“lease” means any lease or tenancy in respect of a residential premises required to be registered by the person chargeable under Part 7 of the Residential Tenancies Act 2004;
“Minister” means Minister for the Environment, Community and Local Government;
“qualifying lease” means a lease granted by the person chargeable to a qualifying tenant;
“qualifying tenant”, in relation to a qualifying lease, means—
(i) a household in respect of which rent is payable by a housing authority—
(I) in accordance with Part 4 of the Housing (Miscellaneous Provisions) Act 2014, or
(II)under a contract under section 19 of the Housing (Miscellaneous Provisions) Act 2009, between the housing authority and the person chargeable,
or
(ii)an individual in respect of whom a rent supplement is payable by, or on behalf of, the Minister for Social Protection;
“register” means the private residential tenancies register maintained by the Board under Part 7 of the Residential Tenancies Act 2004;
“relevant borrowings” means borrowed money employed in the purchase, improvement or repair of a premises or a part of a premises which, at a time interest accrues on the borrowings, is a residential premises let under a qualifying lease;
“relevant interest”, in relation to relevant borrowings and a specified period, means the amount by which the aggregate deductions authorised by subsection (2)(e) are reduced by the application of subsection (2J) in respect of that part of the chargeable periods (within the meaning of section 321) that falls within the specified period and, for the purposes of this definition, interest shall be treated as accruing from day to day;
“relevant undertaking”, in relation to a residential premises, means an undertaking under paragraph (b)(i);
“rent supplement” means any payment under section 198 of the Social Welfare Consolidation Act 2005 towards the amount of rent payable by an individual in respect of a residential premises;
“specified period” means a continuous period of 3 years commencing on or after 1 January 2016 but not later than 31 December 2019.
(b) (i) The person chargeable shall submit to the Board, in such form and containing such information as shall be prescribed by the Minister for the purposes of this subsection, an undertaking to the effect that the person chargeable will let a residential premises under a qualifying lease for the duration of a specified period commencing on—
(I)in the case of a qualifying lease commencing on or after 1 January 2016, the date of commencement of that lease, or
(II)in the case of a lease that commenced prior to 1 January 2016, which would, if the lease commenced on that date, be a qualifying lease, 1 January 2016.
(ii)The Board shall register the relevant undertaking in the register, and the provisions of Part 7 of the Residential Tenancies Act 2004 shall apply to information regarding a relevant undertaking registered in the register as they apply to information regarding a tenancy registered in the register, subject to any necessary modifications.
(iii)A relevant undertaking shall be submitted to the Board under subparagraph (i)—
(I)in the case of a lease referred to in clause (I) of that subparagraph, at the time the person chargeable is required to make an application to register the tenancy under section 134 of the Residential Tenancies Act 2004, and
(II)in any other case, by 31 March 2016.
(iv)Where the person chargeable submits a relevant undertaking in accordance with this paragraph and, following the end of the specified period (in this subparagraph referred to as the ‘first period’), submits a relevant undertaking (in this subparagraph referred to as the ‘subsequent undertaking’) in respect of a subsequent specified period (in this subparagraph referred to as the ‘second period’), the second period shall commence on—
(I)in the case of a qualifying lease commencing on or after the day following the end of the first period, the date of commencement of that lease, and
(II)in the case of a qualifying lease that commenced before the end of the first period, the day following the end of the first period, and
the subsequent undertaking shall be submitted to the Board—
(A)in the case of a lease referred to in clause (I), at the time referred to in subparagraph (iii)(I), and
(B)in any other case, not later than 3 months after the second period commences,
and subparagraph (ii) shall apply to a subsequent undertaking as it applies to an undertaking.
(c)For the purposes of this subsection, where a lease has commenced before 1 January 2016, which would, if the lease commenced on that date, be a qualifying lease and a relevant undertaking is submitted to and registered by the Board, the lease shall be deemed to be a qualifying lease commencing on 1 January 2016.
(d)(i) For the purposes of this subsection, where a qualifying lease (in this subparagraph referred to as the ‘first lease’) terminates during a specified period the currency of that lease shall be deemed to include a period immediately following its termination (in this paragraph referred to as the ‘intervening period’) if—
(I)at the end of the intervening period, the person chargeable grants a subsequent qualifying lease in respect of the residential premises (in this paragraph referred to as the ‘subsequent lease’), and
(II)during the intervening period—
(A)the premises was not let under a lease that was not a qualifying lease,
(B)the person chargeable immediately before the termination was not in occupation of the premises or any part of the premises but was entitled to possession of the premises, and
(C)a person connected (within the meaning of section 10) with the person chargeable was not in occupation of the premises or any part of the premises,
and the first lease and the subsequent lease shall be taken together and treated as one qualifying lease.
(ii) More than one subsequent lease may be granted in respect of a premises under and in accordance with subparagraph (i).
(e) For the purposes of this subsection, where a qualifying tenant ceases to be a qualifying tenant during a specified period, the lease shall nonetheless be treated as a qualifying lease for so much of that period as the tenant occupies the premises under the lease.
(f) This subsection shall apply where the following conditions are met:
(i)a residential premises is let under a qualifying lease for one or more than one specified period, and
(ii)a relevant undertaking in respect of that premises for each specified period is submitted to and registered by the Board.
(g)(i) Subject to this section, a person chargeable who meets the conditions referred to in paragraph (f) may, after the end of the specified period, make a claim to have a deduction authorised by subsection (2)(e) in respect of the residential premises referred to in paragraph (f) computed as if the relevant interest for the specified period accrued on the day immediately following the end of that specified period, and subsection (2J) shall not apply to that relevant interest.
(ii) The relevant interest referred to in subparagraph (i) shall not be included in any computation of relevant interest for a specified period subsequent to the specified period referred to in that subparagraph.
(h)Any claim under this subsection shall—
(i)contain a statement to the effect that the conditions referred to in paragraph (f) are satisfied, and
(ii)be furnished to the Revenue Commissioners by electronic means and through such electronic systems as the Revenue Commissioners may make available for the time being for the purpose of a claim, and the relevant provisions of Chapter 6 of Part 38 shall apply.
(i)Where a premises in respect of which the person chargeable is entitled to a rent is let in part under a qualifying lease and in part under a lease other than a qualifying lease (in this paragraph referred to as the ‘other lease’), the amount of deduction authorised under subsection (2)(e) by reference to interest on borrowed money employed in the purchase, improvement or repair of those premises shall be computed on the amount of interest on that part of the borrowed money which can, on a just and reasonable basis, be respectively attributed to the parts of the premises which are let under the qualifying lease and the other lease.
(j) Notwithstanding section 886, where a person chargeable makes a claim under this subsection, the period for which the linking documents and records (within the meaning of that section) relating to the claim are to be retained by the person required to keep the records under that section shall commence on the final day of the specified period in respect of which the claim is made.
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(3) (a) The amount of the deductions authorised by subsection (2) shall be the amount which would be deducted in computing profits or gains under the provisions applicable to Case I of Schedule D if the receipt of rent were deemed to be a trade carried on by the person chargeable—
(i) in the case of a rent under a lease, during the currency of the lease, and
(ii) in the case of a rent not under a lease, during the period during which the person chargeable was entitled to the rent,
and the premises comprised in the lease or to which the rent relates were deemed to be occupied for the purpose of that trade.
(b) For the purpose of this subsection, the currency of a lease shall be deemed to include a period immediately following its termination, during which the lessor immediately before the termination was not in occupation of the premises or any part of the premises, but was entitled to possession of the premises, if at the end of that period the premises have become subject to another lease granted by the lessor.
(4) (a) Where the person chargeable is entitled in respect of any premises (in this subsection referred to as “the relevant premises”) to a rent or to receipts from any easement and a sum by reference to which a deduction is authorised to be made by subsection (2) is payable by such person in respect of premises which comprise the whole or a part of the relevant premises and other premises, the inspector shall make, according to the best of his or her knowledge and judgment, any appropriate apportionment of the sum in determining the amount of any deduction under that subsection.
(b) Where the person chargeable retains possession of a part of any premises and that part is used in common by persons respectively occupying other parts of the premises, paragraph (a) shall apply as if a payment made in respect of the part used in common had been made in respect of those other parts.
(5) Any amount or part of an amount shall not be deducted under subsection (2) if it has otherwise been allowed as a deduction in computing the income of any person for the purposes of tax.
[2]
Substituted by FA99 s31(1). This section shall be deemed to have come into force and shall take effect as on and from the 20th day of May, 1998.
[8]
Substituted by FA03 s16(1)(a)(i). Applies and has effect in relation to interest referred to in sections 97(2G) and 248A(2) which accrues on or after 6 February 2003 and, for the purposes of this subsection, such interest shall be treated as accruing from day to day.
[9]
Inserted by FA03 s16(1)(a)(ii). Applies and has effect in relation to interest referred to in sections 97(2G) and 248A(2) which accrues on or after 6 February 2003 and, for the purposes of this subsection, such interest shall be treated as accruing from day to day.
[12]
Inserted by FA09 s5. This section is deemed to have come into force and takes effect as on and from 1 January 2009.
[15]
Substituted by F(No.2)A13 sched(1)(a). Has effect as if they had come into operation for the year of assessment (within the meaning of section 2) 2011 and each subsequent year of assessment.