The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:
The corporate interest restriction (CIR) essentially limits the amount of interest expense a company can deduct from its taxable profits if the interest expense is over £2 million. The actual mechanics of the CIR calculation are highly complex (the legislation is over 150 pages long) and are detailed below.
Before looking at the detail of the rules, it is important to note that there are a few points that are specific to the CIR regime, as follows:
The CIR applies to ‘tax interest expense’. This is the legislative phrase used to encompass a wide range of interest and interest-like transactions such as:
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