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Amounts that are disallowed in one accounting period may be carried forward and may potentially be deducted in a subsequent period.

Beyond taking reasonable care to establish that this is the case, companies in such groups are not affected by the rules.

They have no reporting requirements, though they can appoint a reporting company and file an Interest Restriction Return if they wish to. Periods of account straddling 1 April are treated as two notional periods.

Only the notional period commencing 1 April is subject to the Corporate Interest Restriction.


Most multi-national groups have external borrowings on which they pay interest and other financing costs. The borrowings will range from multi-billion syndicated loans used to finance a major acquisition or takeover, to overdraft facilities used to help manage the cash flows of individual companies within the group.

As well as external borrowings, a multi-national group will very often have borrowing arrangements between group companies. The BEPS project was a major and wide ranging initiative by the OECD and G20 countries to limit tax base erosion and the surchargw of profits in such a way that they would bear little or no taxation. This was followed by a point Action Plan, adopted in September Further technical work was conducted on specific areas during and an updated report was issued in December Bythe focus of the BEPS project had shifted to implementation.

The BEPS package as a whole is designed to be implemented via changes in domestic law and practices, and via treaty provisions. Action 4 requires enactment in domestic law. The report put forward extensive best practice recommendations. Thus, multinational groups may achieve favourable tax results by adjusting the amount of debt in a group entity. The influence of tax rules on the location of debt within multinational groups has been established in a number of academic studies and it is well known xtr groups can easily multiply the level of debt at the level of individual group entities via intragroup financing.

Financial instruments can also be used to make payments which are economically equivalent to interest but have a dtg legal form, therefore escaping restrictions on the deductibility of interest. The best-practice recommendations in the report include a number of specific elements, some of which are necessary to implement with the recommended approach and some of which are optional.

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The key components are:. Certain other features are allowed to reduce the impact of the provisions on entities that pose less BEPS risk. These include the following. In these circumstances, although an entity might be highly leveraged, the BEPS risk is considered to be reduced due to the nature of the projects and the close link to the public sector.

This would have a smoothing effect, reducing the impact of earnings and interest rate volatility. The report also contemplates targeted rules to prevent circumvention of the measure and address specific risks. As a best practice approach, the report does not prescribe in detail exactly how its recommendations should be implemented as legislation in each jurisdiction.

However, it is anticipated that a co-ordinated implementation of the recommended approach would successfully impact on the ability of multinational groups to use debt to achieve base erosion or to shift profit.

The implementation, operation and impact of the approach will be monitored over time. The rules may restrict groups which borrow in the UK from third parties or intra-group to hold or acquire foreign businesses which do not form part of the UK tax baseand durcharge which borrow from their shareholders or other related parties, as in typical private equity structures.

The rules apply mechanically.

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There is no avoidance or purpose condition for the rules to apply. They apply after most other tax rules, such as transfer pricing and anti-hybrid rules, but before the loss restriction rules. This will allow groups to manage any restriction across their UK businesses. Groups can nominate one company to file for the whole group.


As an alternative, the group ratio method may be applied, under which the net tax-interest deduction is limited by applying the group ratio to tax-EBITDA. Groups which provide public infrastructure, including rental property, can elect to use a different approach for some or all of their companies.

Instead of applying a limit based on a percentage of earnings, the infrastructure rules restrict deductions where the interest is paid to lenders that are related parties or which have recourse to income or assets other than taxable public infrastructure. Interest above the limit is restricted and carried forward indefinitely.

It can be reactivated if there is sufficient interest allowance in a subsequent period. Unused interest allowance is carried forward for use in a subsequent period for up to five years.

Surchargee of the legislation. In addition F No. Transitional and commencement rules are found in F No. Summary of the Rules — the company and the group. Accordingly, the basic calculations are performed at group level for a period of account of the group. A single-company group is possible.

Although the legislation applies to groups of companies, and much of the computational process takes place at group level, it is given effect through a reduction or increase in deductions at the company level.

These links that bind together how the legislation operates at group and at company level are a pervasive feature of sucrharge Corporate Interest Restriction. For instance, group members subject to corporation tax, known as UK group companies, may be subject to a disallowance of some or all of their net tax-interest expense, or the reactivation of amounts previously disallowed. Similarly, some of the amounts required for the group level calculations, notably aggregate net tax-interest expense and aggregate tax-EBITDA are based on figures of net tax-interest expense and tax-EBITDA that are taken into account in computing profits or losses subject to corporation tax, at the level of the UK group company.

In a similar way, the net tax-interest expense amounts previously disallowed and available for reactivation in a later period are attributable to a company and may be available even where it becomes a member of a different group.

Conversely, any unused interest allowance from an earlier period of a group is a group attribute and does not transfer with a company if it becomes a member of a different group. It is expected that compliance with the rules will usually be managed at the group level by a reporting company.

This will normally be appointed by the group, but HMRC can also appoint one in certain cases. Where the period of account is not exactly a year in length the de minimis amount chadge the period is adjusted pro-rata by day count.

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Under the interest restriction rules, all groups are able to deduct their current period net tax-interest expense up to the de minimis amount. To determine whether a group falls within the de minimis amount, it is only necessary to establish its membership, and that its aggregate net tax-interest expense is less than the de minimis amount or, indeed, that it has aggregate net tax-interest income. No reporting requirements would generally apply to companies in such groups.

However, if a reporting company is in place for a period of account it will need to file at least an abbreviated return for that period. There is no obligation on a group to appoint a reporting company. Surcgarge a group is able to satisfy itself that it is not liable to interest restriction, then it may decide there is no benefit from having a reporting company.

HMRC also has the right to appoint a reporting company, but does not intend to use this power on a speculative basis or where there is no indication the group might be subject to an interest restriction. Rt, if a group wants to calculate and use carried forward unused interest allowance from a period, it must file a full return for that period and any subsequent period before that in which the allowance is used.

In this case, it should appoint a reporting company within the statutory time limits to allow the full return to be filed. Note that the reporting company is permitted to file an abbreviated return for a period surchadge which it does not suffer an interest restriction. It can subsequently, within five years of the period of account, submit a revised full return to establish the carried forward tdr available in a later period.

For further discussion of the possible future benefits of appointing a reporting company and submitting an abbreviated return, even where no interest restriction surcyarge due, see CFM Interest capacity, allowances and disallowances.


A worldwide group will suffer a disallowance where its aggregate net tax-interest expense for the period of account exceeds its interest surcjarge for the period. Where periods of account are not exactly 12 months long, including on commencement, where a period is treated as starting on 1 Aprilthe de minimis amount for the period is computed pro-rata by day count. A relevant company is one that is a member of the group for all or part of a period of account.

As the amounts concerned e amounts taken into account for corporation tax or those that would be but for these rulesonly companies subject to corporation tax need be considered. This will result in either net tax-interest chatge where expenses exceed income, or net tax-interest income where income exceed expenses.

If a company has net tax-interest expense its net tax-interest income amount is zero and vice versa. Note that although the amount is referred to as the aggregate tax-interest expense of a worldwide group, only amounts relating to UK group companies are taken into account in the calculation.

In this calculation, no distinction is made between intra-group and external amounts. The rules use two closely related concepts: The interest capacity, which takes into account the de minimis amount, limits the amount of aggregate net tax-interest expense arising in the current period that can be deducted. The interest allowance is a function of any aggregate tax-EBITDA and any aggregate net tax-interest income for the period. The interest allowance feeds into the interest capacity, but it is the unused interest allowance that can be carried forward or used to reactivate carried forward tax-interest expense.

The interaction between interest capacity and interest allowance prevents de minimis amounts from being carried forward or being used in place of carried forward interest allowance. The interest capacity, the figure actually taken surchagge account in computing disallowances, is calculated from the basic interest allowance and augmented by any unused interest allowance for earlier years. Where the period of surchrge is longer or shorter than a year, chafge de minimis amount available for the period is adjusted proportionately.

The interest allowance for the period is the sum of surchwrge basic interest allowance and the aggregate net tax-interest income for the period of account.

This aspect of the calculation is only relevant to amounts carried forward, because if there is aggregate net tax-interest dte in a period there is no aggregate net tax-interest expense is to restrict. There is a default order in which different types of tax-interest expense deductions are disallowed, which the company may elect to vary.

In groups with a reporting company, the pro-rata amount is also the maximum disallowance that can be allocated to a group member that has opted not to consent to discretionary allocations made by the reporting company. The amounts disallowed at company level become a tax attribute of the company.

The group can elect which companies reactivate the amounts they carry forward. Reactivated amounts are chargr as current period expenses of the same type surcjarge the amounts previously disallowed. The fixed ratio method. Of the two methods applied in computing the basic interest allowance of the worldwide group for a period of account, the simpler method used by default, is the fixed ratio method. The tax-EBITDA of a company is a measure of its earnings before interest, tax, depreciation and amortisation, but computed according surchafge corporation tax rules.

The amounts for the UK group companies that were members of the worldwide group at any time in xurcharge period of account are aggregated to produce the aggregate tax-EBITDA of a worldwide group for a period of account. It is an accounting-based measure. The specific categories of income and expense which fall within net group-interest expense are set out in the legislation.

The measure of external interest expense used to compute the fixed ratio debt cap is the adjusted net group-interest expense of the group ANGIE.

This surccharge computed by making specific upwards and downwards adjustments to the net group-interest expense of the group for the period of account. These adjustments align the measure more closely with the type and timing dfr amounts included in net tax-interest.