Commentary

# D1.1429 Calculating the corporate interest restriction group ratio percentage and applying the group ratio method

##### Corporate tax
Corporate tax | Commentary

#### D1.1429 Calculating the corporate interest restriction group ratio percentage and applying the group ratio method

Corporate tax | Commentary

## D1.1429 Calculating the corporate interest restriction group ratio percentage and applying the group ratio method

### Calculating the group ratio percentage

The purpose of the group ratio percentage is to apply an alternative percentage to tax- EBITDA as opposed to the default rate of 30% under the fixed ratio method. There would be no advantage in making a group ratio election if the GRP was less than 30%.

The GRP is computed using the formula:

GRP = (QNGIE ÷ group-EBITDA) × 100/1.

In those rare situations where QNGIE is greater than group-EBITDA, GRP is capped at 100%. Furthermore, if the formula would otherwise produce

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