The Corporate Interest Restriction ("CIR") rules are an important part of any Group's tax compliance requirements. The rules have been in place for several years, are complex, and can be difficult to apply. There have also been a number of recent changes to how CIR returns and notifications can be submitted to HMRC, and the information that is required.
The earliest CIR returns are now beyond the point where they can be amended, and some CIR attributes will now start to lapse. In the run up to what is for many a key filing deadline at the end of December, it will be important to consider the CIR position as early as possible, making sure notifications have been submitted and elections considered where necessary.
Read more below for some considerations and how PwC can help with CIR modelling, calculations, elections and preparation or review and submission of returns.