Commentary

D1.1465 Corporate interest restriction (CIR)—HMRC enquiries

Corporate tax
Corporate tax | Commentary

D1.1465 Corporate interest restriction (CIR)—HMRC enquiries

Corporate tax | Commentary

Corporate interest restriction—HMRC enquiries

D1.1465 Corporate interest restriction (CIR)—HMRC enquiries

The procedures for corporate interest restriction (CIR) enquiries are based on the provisions of Finance Act 1998, Sch 18 as adapted to match the circumstances related to the CIR1.

Enquiry into interest restriction return

HMRC may enquire into an interest restriction return by serving notice on a reporting company. As a general rule, an interest restriction return will only be subject to one notice. HMRC may enquire into the original return, any amended return or both subject to the protection discussed in the 'Scope of enquiry' section below.

The power to enquire into the interest restriction return does not affect the power to enquire into the corporation tax return of a member of the group. This means that an interest restriction return enquiry could result in an amendment of a company tax return even though a closure notice was previously issued.

Time limits

The rules on normal time limits for opening an enquiry into an interest restriction return reflect the exceedingly long time limit of 36 months for submission of a revised return.

Notice of enquiry may be served on the reporting company on the latest of the following three

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