Commentary

D1.1403 Carried forward amounts

Corporate tax
Corporate tax | Commentary

D1.1403 Carried forward amounts

Corporate tax | Commentary

D1.1403 Carried forward amounts

Carry forward provisions for the corporate interest restriction (CIR) regime have been created as a policy response to the potential fluctuations in a group's profitability, interest rates and other factors. Although these rules have been inserted as a means of reducing the impact of these fluctuations, they do add considerably to the complexity of the regime1.

See D1.1435 for further details of the CIR carry forward provisions.

Carry forward of disallowed interest

Interest expense that is disallowed under the CIR may be carried forward indefinitely and claimed as a deduction in a later period, provided there is sufficient capacity within the group's interest allowance for that later period. This is known as 'interest reactivation'. Interest reactivation is not

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