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International Tax Reform

A new era for aviation structuring

The soon-to-be-introduced Interest Limitation Rules will impact on the manner and extent of debt financing introduced into, particularly, an Irish aircraft leasing platform, states Deloitte.

The introduction of the Interest Limitation Rules (ILR)

The new decade began with numerous countries globally shutting down their borders in response to the arrival of Covid-19. The aviation industry was and continues to be impacted greatly by the spread of coronavirus, with the number of global passengers decreasing dramatically and record numbers of aircraft on the ground.

In this article, we focus on a far reaching development that will impact on the  manner and extent of debt financing introduced into, particularly, an Irish aircraft leasing platform. This development is the impending introduction of the Interest Limitation Rules (ILR) as is required under Article 4 of the EU Anti-Tax Avoidance Directive (EU ATAD) into Irish tax law with effect from 1 January 2022.

This article first appeared in the Air Finance Journal 2021/22 and can be found here.

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