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The Corporate Interest Restriction - Where are we now?

2 Part Course  |  Learn how the CIR rules work to ensure compliance with them and to avoid the pitfalls and elephant traps.

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

The Background to the CIR Rules

A view of the CIR rules from 30,000 feet

What happened to the worldwide debt cap rules?

Key principles:
  • Is it just “interest”?
    • Loan relationship debits
    • Derivative contract debits
    • Implicit finance costs under finance leases and debt factoring.
    • Guarantees
  • What is the Worldwide Group?
  • Which accounting standards apply?
  • What periods does it apply to?
  • The £2m de minimis threshold.
  • The interest restriction
  • Carry forward of disallowed interest.
  • The Public Infrastructure Exemption
    • Rationale
    • Election, revocation, and consequences.
  • Reporting companies
  • Consenting companies
  • Interest restriction returns
  • Timing
  • Determinations absent a compliant return
  • Contents of the return
  • Abbreviated returns
  • Revision
  • Penalties
  • Enquiries
  • Company tax returns and changes
  • Preservation of records
  • Provision of information.
  • Electronic filing
Calculating and applying the interest restriction.
  • Net-tax interest expense
  • The group’s aggregate net-tax interest expense.
  • Calculating interest capacity
Calculating the interest allowance: an introduction.
  • the fixed ratio rule.
  • the group ratio rule.

Part Two

The fixed ratio rule – a default mechanism in detail
  • 30% of aggregate tax-EBITDA
    • Calculating tax-EBITDA
      • Adjusted corporation tax earnings
    • Aggregate tax-EBITDA
  • Fixed ratio debt cap
    • ANGIE
      • Calculating NGIE
      • Upward and downward adjustments to NGIE
The Group ratio rule in detail
  • Group EBITDA
  • Interest allowance (alternative calculation) election
  • Interest allowance (non-consolidated investment)election
  • Interest allowance (consolidated partnerships) election
  • Group -EBITDA (chargeable gains) election
  • Group ratio (blended) election
Carried forward disallowed interest
  • What level?
  • Reactivation
    • Calculation
    • Tax treatment
  • Groups in a net interest position
Caried forward unused interest allowance.
  • Unused
  • Available
  • Expiry
Treatment of capitalised interest

Adjustments for leases where International Financial Reporting Standards (IFRS) 16 is used


Other matters

This course will include Q&As
Regular pauses for questions on each topic covered to take questions and queries

Our trainer advises on all areas of revenue law, both corporate and personal, but has a particular interest in corporate tax matters including, acquisitions and disposals, reconstructions and demergers, MBOs, returning capital to shareholders, s425 schemes, SDLT, stamp duty and SDRT.

He has a special expertise in the taxation of insolvent companies, members' voluntary liquidations (including s110 schemes) and bankruptcy, and lectures regularly to R3 and is a member of the R3/HMRC liaison group which meet regularly to discuss issues of conflict between insolvency law and tax law. 

Over the years he has been involved in advising on the tax aspects of some of the UK's major insolvencies including Maxwell, Pollypeck, BCCI, Olympia and York, Mayflower, ITVdigital, MFI, Allied Carpets, Borders, Farepak and Lehman Bros.  He is a Fellow of the Association of Business Recovery Professionals (FABRP) having passed the JIEB examinations.
Following his call to the bar by Middle Temple in 1986 and pupillage in insolvency chambers (3/4 South Square) where he was pupil to the late Gabriel Moss QC and tax chambers (Pump Court) he joined Paisner & Co (now Bryan Cave Leighton Paisner) before moving on to Allen & Overy.  In 1993 he joined Coopers & Lybrand (now PwC) and then in 1996 Deloitte, where he was made a corporate tax partner in 1999.

In 2008, fearing he would be found dead in his hutch under a pile of budgets, appraisals and forecasts he returned to the Bar and joined Temple Tax Chambers.

  • Understand when a company or group may face a disallowance of ‘excess’ interest expense
  • Calculate whether a disallowance is necessary
  • Identify when an abbreviated CIR return might be needed and what to do if one should have been filed for earlier periods.
  • Identify and understand the various elections that can be made and what effect they have on the calculations.  Should you make them or not?
  • Understand how disallowed interest can be relieved (‘reactivated’) in future periods
  • Understand how unused amounts can be carried forward and used in future periods
  • Be prepared in case there is ever a question on the CIR in your local pub quiz, it may be the difference between winning and losing.

  • The webinar looks at both the theory and practice of the rules to give you a deeper understanding of how they apply. 
  • Examples will highlight the points being made.
  • It is presented by a barrister with over 35 years’ experience in tax.
  • The course will encourage participation and allow for all questions and clarifications to be considered.
  • The corporate interest restriction course is up to date with the changes made in the Finance (No 2) Act 2023 and is both current and relevant. Amendments to the contents of the webinar will be made as and when changes to law and practice arise which may necessitate a change in the order of the materials.

This 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 expect to incur, net interest expense of more than £2 million a year where a CIR return might be either mandatory or beneficial to submit.
The corporate interest restriction course is a ‘nice to know’ for;
  • CFOs, FDs and FCs seeking to understand why interest incurred is disallowed for tax purposes and how to manage it.

This corporate interest restriction webinar will help attendees understand when there might be a disallowance a company’s interest under the corporate interest restriction rules.

Delegates will be able to identify which companies are relevant to the calculations and when group companies can be disregarded under the Public Infrastructure Exemption.

Those attending will learn the mechanics of the calculation including examining the main features of each variable that forms part of the calculations and how they can be affected by available elections.

Where a company or group may face a disallowance in future years delegates will understand the necessity of filing abbreviated returns.
Number of places:
Part 1

£ 695.00

Number of places:
Part 2

£ 695.00

Discounts available:

  • 2 places at 30% less
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  • 4 places at 50% less
  • 5 places at 55% less
  • 6+ places at 60% less
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