When you calculate how much UK Corporation Tax a company or group has to pay, it’s important to bear in mind that there is a Corporate Interest Restriction (“CIR”) which applies to individual groups of companies that have net interest and financing costs of over £2 million in a 12-month period. This limits the amount of tax relief available in relation to net interest and other financing costs. Further information about the CIR legislation is available on GOV.UK.
HMRC is aware of various technical issues with the CIR legislation and is in the process of setting up a working group to consider these issues and how we can help resolve them. HMRC is keen to hear your views. If you would like to join the CIR working group, please contact Jackie Phillips by email: jackie.phillips@hmrc.gov.uk.