The Corporate Interest Restriction

Redcliffe’s Corporate Interest Restriction training course is led by a seasoned tax professional who is the director of a consultancy firm specialising in taxation, share schemes, and reward strategies. With a wealth of experience advising both small companies and FTSE-listed corporations, he has developed a specialised share scheme service tailored for SMEs, while also guiding large corporates on effective communication strategies. His passion lies in employment taxation and transfer pricing, areas with conceptual complexities.

Having previously led the Share Schemes team at Henderson during his 9-year tenure, he completed a CIPD Level 7 Master's qualification, solidifying his expertise in reward and employee compensation strategies. Before that, while working for the Australian Mutual Provident (AMP), he played a pioneering role in establishing one of the first Share Incentive Plans (SIPs) for large companies in 2001. His work was so innovative that HMRC reached out to learn how more companies could be encouraged to adopt SIPs.

His early career saw him in senior roles at three of the “Big Four” accountancy firms, including Deloitte, where he rose to Senior Manager. His work spanned profit-related pay, expatriate tax, tax investigations, reward management, US taxation, and corporate tax, giving him a broad foundation in complex tax matters.

Outside of his professional pursuits, he enjoys cricket, history, skiing, tennis, and gardening, and frequently lectures on historical topics to keep his presentation skills sharp and engaging.

• This CIR course covers how to determine whether a company qualifies for exemption under the Public Infrastructure Exemption rules.
• Participants will 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 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.
• Finally, interest restriction training includes guidance on building a spreadsheet-based CIR model to automate key calculations wherever possible.

This CIR 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.

Sessions are designed to help attendees understand when companies might face a disallowance of interest under the corporate interest restriction rules.

Training guides 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 during CIR accounting sessions, where there is a possibility that the company or group will face a disallowance in future years.