Corporate interest restriction 鈥� frequently asked questions
Corporation Tax
Guidance
The following scenarios are intended to illustrate how the corporate interest restriction (CIR) will apply in a variety of real-world situations. The scenarios are intended to be more complex than the most simple situations but not uncommon.
For a general overview of the regime, see the Corporate interest restriction 鈥� overview guidance note.
How does the CIR apply if a company鈥檚 accounting periods (APs) do not align with the period of account (PoA)?
Most of the computations and allocations required by the CIR are carried out by reference to a group鈥檚 PoA. UK corporation tax, however, operates by reference to APs of individual companies, which do not necessarily align with the periods for which a group draws up consolidated financial statements. The term used to describe an AP of any group company that falls wholly or partly within a given PoA is a relevant AP.
Where a UK group company鈥檚 APs exactly align with the periods for which its group draws up financial statements, that company will have only one relevant AP and it will
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Produced by Tolley in association with Emma Haley at Boodle Hatfield LLP
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