Corporate Interest Restriction draft guidance
HM Revenue and Customs are seeking comments on this draft guidance covering the new Corporate Interest Restriction rules.
This draft guidance has been published so that stakeholders can comment on it and to explain the application of the Corporate Interest Restriction legislation. The legislation was included in Schedule 10 of Finance Bill 2017 but that schedule was removed from the bill. There has been no policy change and the government has announced it will legislate for the provisions at the earliest opportunity in the next Parliament.
This is an initial tranche of guidance, focusing on the core rules and other aspects where guidance has been specifically requested. Amended and further draft guidance will be issued after the measure is re-introduced.
Comments about this draft guidance should be emailed to the Corporate Interest Restriction team at firstname.lastname@example.org. Comments can sent in batches. A deadline for comments will be set after the second tranche is issued.
The draft guidance will be updated as necessary in the light of comments received.
A consultation on the corporate interest restriction has been carried out.
Two sets of draft regulations have also been published for this measure dealing with collective investment vehicles and securitisation companies and group mismatches.
A tax information and impact note has also been published.