Corporate interest restriction

FORTHCOMING CHANGE relating to corporate interest restriction administration simplification: On 29 April 2025, the UK government announced that it would be engaging with stakeholders on opportunities to simplify and improve the corporate interest restriction administration rules—in particular, around the appointment of reporting companies. Stakeholders with relevant technical expertise were invited to join an HMRC working group to take this forward. See News Analysis: Tax update spring 2025—Tax analysis—Corporation tax and international.

The rules comprising the corporate interest restriction (CIR) were introduced with effect from 1 April 2017 in order to tackle erosion of the UK tax base through the use of interest deductions.

The main rules are found in Part 10 of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010), with related administrative provisions being found in TIOPA 2010, Sch 7A. HMRC's published guidance on the CIR can be found in its Corporate Finance Manual, starting at CFM95000.

The CIR rules are lengthy and complex. Many of the key operative provisions are heavily calculations-based, and use multiple defined terms. For an introduction to the CIR rules and a more

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