Corporate interest restriction ― carry-forward amounts

By Tolley

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

  • Corporate interest restriction ― carry-forward amounts
  • Introduction
  • Tax-interest expense disallowance carried forward
  • Unused interest allowance
  • Excess debt cap


Companies may experience variations in business profits and market interest rates. Changes in capital structure that impact the level of debt on the balance sheet may also occur from time to time. These and other sources of volatility could result in disallowances in some periods and unused interest allowances in other periods.

To provide a greater element of fairness in the corporate interest restriction (CIR) rules, there are a number of carry-forward provisions that are set out in the table below:

Tax attributeOwnershipCarry-forward periodStatutory reference
Tax-interest disallowedCompanyIndefinite carry forwardTIOPA 2010, s 378
Unused interest allowanceWorldwide groupFive yearsTIOPA 2010, ss 392–395
Excess debt cap

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