Corporation Tax

Corporate interest restriction ― administrative aspects

Produced by Tolley
  • 05 Nov 2021 06:53

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

  • Corporate interest restriction ― administrative aspects
  • Additional HMRC guidance, templates and worksheets - corporate interest restriction
  • Appointment of a reporting company for CIR
  • Submission of a full interest restriction return
  • Obligation to file and filing deadline
  • Revised returns
  • Contents of interest restriction return
  • Statement of calculations
  • Statement of allocated interest restrictions
  • Statement of allocated interest reactivations
  • More...

Corporate interest restriction ― administrative aspects

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.

Additional HMRC guidance, templates and worksheets - corporate interest restriction

The following worksheets containing embedded information are available on the Government website:

  1. worksheet for the appointment of a reporting company

  2. abbreviated interest restriction return

  3. full interest restriction return for up to 10 companies

  4. full interest restriction return for up to 25 companies

  5. 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 for CIR

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

The reporting company must:

  1. not be dormant

  2. be subject to UK corporation tax for at least part of the return period, and

  3. 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

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