Corporate interest restriction ― administrative aspects

By Tolley
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The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Corporate interest restriction ― administrative aspects
  • Introduction
  • Additional HMRC guidance, templates and worksheets
  • Commencement provisions
  • Appointment of a reporting company
  • Submission of a full interest restriction return
  • Contents of interest restriction return
  • Completion of an abbreviated interest restriction return
  • Enquiry into interest restriction return
  • Penalties

Introduction

This guidance note deals with the main administrative aspects of the corporate interest restriction (CIR) regime. Many of the principles have been borrowed from existing administration provisions, such as those in FA 1998, Sch 18, but new provisions are required due to the nature of the calculations. Many of the calculations are carried out on a worldwide group basis, although disallowances or reactivations of the interest expense must ultimately be reflected in the computations of the individual companies subject to UK corporation tax.

This guidance note does not include commentary on provisions that are substantially the same or similar to the general administration requirements for corporation tax returns. For a full analysis of all the administration provisions around CIR, see Simon’s Taxes D1.1445 et seq (subscription sensitive).

The provisions are contained in TIOPA 2010, Sch 7A. Explanatory notes published on 8 September alongside Finance (No 2) Act 2017 are available here .

References in this guidance note are to HMRC’s guidance . This guidance is in the process of being transitioned into the Corporate Finance manual but until all the content is available in the manual, it is necessary to refer to the guidance .

The latest version of HMRC’s guidance includes commentary on additional technical changes to ensure the regime works as intended which are contained within Finance Act 2018, s 24 and Sch 8.

HMRC guidance on the CIR administrative rules is set out in CFM98400 onwards, with an overview in CFM98410.

Additional HMRC guidance, templates and worksheets

The following worksheets containing embedded information are available on the Government website:

  • worksheet for the appointment of a reporting company
  • abbreviated interest restriction return
  • full interest restriction return for up to 300 companies
  • full

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