Corporate interest restriction ― administrative aspects

By Tolley
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The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • Corporate interest restriction ― administrative aspects
  • Additional HMRC guidance, templates and worksheets
  • Appointment of a reporting company
  • Submission of a full interest restriction return
  • Contents of interest restriction return
  • Completion of an abbreviated interest restriction return
  • Enquiry into interest restriction return
  • Penalties

The corporate interest restriction (CIR) regime has some specific administrative rules in addition to the general administrative requirements for corporation tax returns.

TIOPA 2010, Sch 7A

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.

Additional HMRC guidance, templates and worksheets

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.

Appointment of a reporting company

The vast majority of groups affected by the CIR will choose to appoint a reporting company for the group.

TIOPA 2010, Sch 7A, Part 1, para 1; CFM98470

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) (or six months for

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