Commentary

D1.1404 Interest restriction returns, other tax administration and regime anti-avoidance rule

Corporate tax
Corporate tax | Commentary

D1.1404 Interest restriction returns, other tax administration and regime anti-avoidance rule

Corporate tax | Commentary

D1.1404 Interest restriction returns, other tax administration and regime anti-avoidance rule

Administrative aspects of the corporate interest restriction regime

The main corporate interest restriction (CIR) administration provisions include the following1:

  1.  

    •     a reporting company must prepare and submit interest restriction returns for the group—penalties will be levied for failure to do so within the relevant time limits or for the submission of an inaccurate return

  2.  

    •     the main function of the full return is to allocate interest restrictions and reactivations (if any) with calculations and elections such as the group income election discussed above

  3.  

    •     an abbreviated return may be submitted where

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