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
**Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason.
Access this article and thousands of others like it free for 7 days with a trial of TolleyGuidance.
Read full article
Already a subscriber? Login
Interest can best be thought of as compensation for the use (or retention) by one person of a sum of money which belongs to another. Therefore, in order for a payment to be interest, there must be a principal sum on which the interest is calculated and both amounts (the principal and the interest)
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marked the end of the Brexit transition / implementation period entered into following the UK’s withdrawal from the EU. At this point in time, key transitional arrangements came to an end and significant changes began to take effect across the UK’s
Working rule agreements are used in the construction industry and similar areas. They are national agreements made between trade unions and employers across the country, setting out the terms and conditions that apply to particular categories of hourly paid manual workers. The workers concerned are
IntroductionTax equalisation is widely used by multi-national companies or group moving employees from one country to another. It is not a statutory concept but is an arrangement between an employer and employee.The idea behind tax equalisation is that an employee accepting an assignment somewhere