The following Corporation Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
The corporate interest restriction (CIR) regime has some specific administrative rules in addition to the general administrative requirements for corporation tax returns.
This guidance note does not include commentary on provisions that are substantially the same or similar to the general administration requirements for corporation tax returns. For a full analysis of all the administration provisions around CIR, see Simon’s Taxes D1.1445 onwards.
HMRC guidance on the CIR administrative rules is set out in the Corporate Finance manual at CFM98400 onwards, with an overview in CFM98410.
The following worksheets containing embedded information are available on the Government website:
worksheet for the appointment of a reporting company
abbreviated interest restriction return
full interest restriction return for up to 10 companies
full interest restriction return for up to 25 companies
full interest restriction return for up to 300 companies
To access the above material, see Submit a Corporate Interest Restriction return.
In addition to the HMRC guidance referred to above, companies are also advised to contact their HMRC customer compliance manager (CCM) for further information.
The vast majority of groups affected by the CIR will choose to appoint a reporting company for the group.
The reporting company must:
not be dormant
be subject to UK corporation tax for at least part of the return period, and
have its appointment authorised by at least 50% of eligible companies in the group
Notice must be given to HMRC within 12 months of the end of the specified period of account (PoA). This notice must specify the first PoA to which the appointment relates and must be accompanied by a list of the eligible authorising companies and a statement that those companies constitute at least 50% of the eligible companies.
The appointment is effective for the specified PoA and subsequent PoAs of the group.
The appointment of the reporting company can be revoked using a procedure similar to the appointment one
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