Commentary

D1.1445 Corporate interest restriction (CIR)—administrative aspects

Corporate tax
Corporate tax | Commentary

D1.1445 Corporate interest restriction (CIR)—administrative aspects

Corporate tax | Commentary

Corporate interest restriction—administrative aspects

D1.1445 Corporate interest restriction (CIR)—administrative aspects

This article deals with the main administrative aspects of the corporate interest restriction (CIR) rules. Many of the principles have been borrowed from existing administration provisions such as those in Finance Act 1998, Schedule 18 but additional 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 individual companies subject to UK corporation tax. The provisions are self-contained within TIOPA 2010, Sch 7A1.

Corporate interest restriction commencement provisions

The CIR provisions apply in relation to periods of account of worldwide groups beginning on or after 1 April 20172.

Transitional rules apply if the period for which the financial statements are drawn up is for 18

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