UK corporate interest restriction (CIR): lawyers' overview of scope, group computations, fixed/group ratio caps, £2m de minimis, carry forward, elections, exemptions, sector-specific rules and interest restriction returns
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Practice notes
The corporate interest restriction (CIR) rules are extensive and technically demanding. This Practice Note serves as a primer to the CIR and points readers to further detail in related materials:
- Practice Note: Corporate interest restriction—glossary of key terms, explaining key expressions and concepts used across the legislation
- Practice Note: Corporate interest restriction—the main rules, providing an in‑depth overview of the core operative provisions
- Practice Note: Corporate interest restriction—administration, covering procedural matters, including the interest restriction return
- Practice Note: Corporate interest restriction—elections, outlining the various elections a group may include in its interest restriction return
The regime has applied since 1 April 2017. The principal provisions appear in Part 10 of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010), with associated administrative rules in TIOPA 2010, Sch 7A. HMRC guidance is set out in the Corporate Finance Manual, beginning at CFM95000.
Background to the CIR
As an element of the G20/OECD initiative addressing Base Erosion and Profit Shifting (BEPS), the OECD issued best practice recommendations in 2015 aimed at preventing erosion of the tax base by multinational groups through the use of deductions for...
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Web page updated on 27/05/2026
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