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Corporate Interest Restriction - What Action Should You Be Taking?

2 Part Course  |  Understand what actions may be needed now to ensure compliance with the CIR rules

Corporate Interest Restriction Course

A one-day course presented in two half-day live webinars

This course is a ‘must know’ for;
  • Tax professionals preparing corporation tax computations for companies and/or groups of companies that incur, or expect in the near future to incur, net interest expense in excess of £2 million per annum where a CIR return might be mandatory or beneficial to submit.
The course is a ‘nice to know’ for;
  • CFOs, FDs and FCs seeking to understand why interest incurred is disallowed for tax purposes.

  • The course is highly practical and will include multiple examples to assist with understanding the rules
  • It is presented by an independent training professional and can be a completely independent look at the issues raised
  • The course will encourage participation and allow for all questions and clarifications to be considered
  • The course will always be completely current and relevant

  • Identify if a company can be exempted from the rules under the Public Infrastructure Exemption
  • Understand the situations in which a company or group may face a disallowance of ‘excess’ interest expense
  • Calculate the variables needed to identify is a disallowance is necessary
  • Identify when it is beneficial to file an abbreviated CIR return and what to do if one should have been filed for earlier periods
  • Understand the elections that can be made to vary the amounts used in the calculations and the pros and cons of using them
  • Understand how disallowed interest can be relieved (‘reactivated’) in future periods
  • Understand how unused amounts can be carry forward and used in future periods
  • Create a spreadsheet model to automate as many of the calculations as possible

Part One

  • Acceptable bases of preparing financial statements for CIR purposes
  • Identifying the worldwide group
  • What to do if you cannot obtain financial information about group companies in other jurisdictions
  • Public Infrastructure Election – when it can be made and the pros and cons of doing so
  • Appointing a reporting company
  • Asking HMRC to appoint a reporting company
  • Interest allowance – the fixed ration rule and its variables
  • Interest allowance – the group ratio rule and its variables
  • Interest capacity – the £2 million de-minimis rule
  • Examples of calculating the above
  • UK tax-interest expense – definition, what is included and excluded, with examples
  • Aggregate UK tax-EBITDA – deriving the correct figure from the accounts and from tax law with examples
  • Adjusted (worldwide) net-group interest expense (“ANGIE”) – what is included and excluded with examples
  • Treatment of capitalised interest and elections that can vary the basic treatment

Examples used during the course:

  • Worldwide group evaluation
  • Reporting company appointment
  • Filing abbreviated returns
  • Fixed ratio rule interest allowance
  • Group ratio rule interest allowance overview
  • CIR calculation examples
  • ANGIE
  • Capitalised interest election

This course will include Q&As

  • The opportunity to raise examples you have come across and discuss the tax implications
  • Regular pauses for questions on each topic covered to take questions and queries

Part Two

  • The Group Ratio rule – calculating the group ratio
  • Qualifying net group interest expense – how it is derived from ANGIE
  • Meaning of related party interest expense – inclusions and exclusions with examples
  • Worldwide group EBITDA – adjustments needed to the worldwide consolidated EBITDA with examples
  • Adjustments where UK companies have foreign income suffering tax at source
  • Treatment of unused interest allowances from previous years
  • Treatment of disallowed interest from previous years
  • Excess debt cap carried forward – maximising the interest deduction each period
  • Worldwide group EBITDA elections – chargeable gains, tax-interest, pension contributions, employee share acquisitions, changes in accounting policy
  • Use of blended rate in the group ratio rule where a group is owned by corporate shareholders
  • Adjustments for leases where IFRS 16 is used
  • Case study example and spreadsheet solution

Examples used during the course:

  • QNGIE
  • Related party interest identification
  • Excess debt cap carried forward
  • Reactivation of previous years’ disallowed interest
  • Unused allowances brought forward
  • Case study bringing in all knowledge gained from the course
  • Using a spreadsheet to model CIR calculations to minimise the resource needed

This course will include Q&As

  • The opportunity to raise examples you have come across and discuss the tax implications
  • Regular pauses for questions on each topic covered to take questions and queries

The trainer is a UK Chartered Accountant and Chartered Tax Advisor winning the John Wood Medal in the November 1995 CIOT sitting for the best paper on business taxation.

He was previously Director of Finance and Taxation Programmes at BPP Professional Education and has delivered IFRS, US GAAP, UK Tax and VAT to a multitude of organisations world-wide since 1992.

He has particular experience in delivering bespoke IFRS and US GAAP training programmes to multi-nationals in the financial services, transport and energy sectors as well as delivering UK tax and VAT update programmes to accounting and law firms.

The trainer is passionate about training and his enthusiasm ensures that the participants enjoy the learning experience whilst gaining knowledge through their engagement in the sessions and through encouraging them to ask questions and discuss practical issues they may have.

He also provides consultancy services to companies and accounting firms, including provision of tax and VAT advice, reviewing accounting policy manuals and advising on accounting treatments of various transactions.

This course is designed to help attendees understand when companies might face a disallowance of interest under the corporate interest restriction rules.

It will guide delegates through the process of identifying which companies are relevant to the calculations and whether any group companies can be disregarded under the Public Infrastructure Exemption.

Delegates will learn the mechanics of the calculations and how these can be modelled in a spreadsheet to save time each year. They will be taken through the main features of each variable that forms part of the calculations and how the variables can be affected by elections that can be made.

The importance of filing abbreviated returns will be highlighted where there is a possibility that the company or group will face a disallowance in future years.

  • The ability to discuss points and ask for additional information on scenarios which we had come across. The trainer really knows what he is talking about, explains it very clearly and if he ever has to check something in response to a question, he comes back with the answer carefully thought out and linked to the legislation.
  • The instructor did a very good job overall of explaining the details of this very complicated regime; what the terms meant and where to find the information to calculate these variables.
Number of places:
Part 1
Number of places:
Part 2

£695.00

Per participant per part
Discounts available for multiple place booking find out more
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