Interest limitation rules – exemption for certain large scale assets
In an unexpected move, the scope of the current exemption from the interest limitation regime which applies to providing, upgrading, operating or maintaining certain large scale assets (such as renewable energy installations, strategic housing developments and public-private partnership (PPP) roads) where relevant conditions are met is extended. The extensions to the exemption include electricity transmission infrastructure developments, strategic gas infrastructure developments, strategic infrastructure developments and large-scale residential developments, as defined in the Planning and Development Act 2024 where a decision to grant permission for that development has been made under that Act.
This encompasses a broad range of infrastructure assets such as transmission lines, substations and switching stations, electricity interconnectors, downstream gas pipelines, surface storage of natural gas, natural gas terminals, waste-water treatment plants, waste incinerators, certain harbour and port installations, thermal power stations and certain healthcare infrastructure.
This is a welcome development and will give investors and developers of these projects more certainty regarding the tax treatment of their financing costs. The amendment is subject to the passing of a Ministerial Order.