UK: Draft legislation – Corporate Interest Restriction

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The Corporate Interest Restriction (CIR) legislation was included in Schedule 10 of Finance Bill 2017 but has now been removed. There has been no policy change and the government has announced it will legislate for the provisions at the earliest opportunity in the next Parliament.

A consultation on how the CIR rules should operate was opened in May 2016 and the government’s response to this was published in December 2016.

Regulations are needed to ensure the interaction of the rules with accounting standards does not give an unwarranted restriction on commencement of the CIR. In particular, they deal with timing differences between the group and entity accounts when applying the fixed ratio debt cap and also for the group ratio method for highly leveraged groups.

HM Revenue and Customs has published draft regulations, together with a draft explanatory memorandum, for a period of consultation which will close on 26 May 2017.

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