2 Part Course  | 
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The Corporate Interest Restriction - Where are we now?

2 Part Course  |  Learn what actions may be needed now and how to ensure compliance with the CIR rules.

Green and Red leaves a contrast of color that is both vibrant and calming

A one-day course presented over two-half days in a virtual class from 9:30am to 1:00pm UK time

Part One

  • Acceptable bases of preparing financial statements for CIR purpose
  • 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
  • Capitalised interest election as corporate interest restriction legislation

This course will include Q&As

  • The opportunity to raise examples you have come across and discuss the corporation 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 corporate interest restriction group is owned by corporate shareholders
  • Adjustments for leases where International Financial Reporting Standards (IFRS) 16 is used
  • Case study example and spreadsheet solution

Examples used during the course:

  • 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 CIR tax implications
  • Regular pauses for questions on each topic covered to take questions and queries

Our 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 worldwide since 1992.

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

Our 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 the provision of tax and VAT advice, reviewing accounting policy manuals and advising on accounting treatments of various transactions.

  • 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 if a disallowance is necessary.
  • Identify when it is beneficial to file an abbreviated CIR (corporate interest restriction) 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 carried forward and used in future periods.
  • Create a spreadsheet CIR model to automate as many of the calculations as possible.

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

Our corporate interest restriction course is a ‘must know’ for:

  • Tax professionals preparing corporation tax interest allowable on computations for companies and/or groups of companies that incur, or who shortly expect to incur, net interest expense over £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.

Our corporate interest restriction webinar is designed to help attendees understand when companies might face a disallowance of interest under the corporate interest restriction guidance 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.

CIR management 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.

Number of places:
Part 1

£ 695.00

Number of places:
Part 2

£ 695.00

Discounts available:
Virtual Class

  • 2 places at 30% less
  • 3 places at 40% less
  • 4 places at 50% less
  • 5 places at 55% less
  • 6+ places at 60% less
  • Select the number of course places and dates to automatically calculate the discount
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