Restriction on Corporation Tax relief for interest deductions
Check if your company’s or group’s interest deductions for Corporation Tax will be restricted, and if you need to send a Corporate Interest Restriction return.
When you work out how much UK Corporation Tax your company or group has to pay, there’s a limit (known as a Corporate Interest Restriction). This limits the amount of tax relief you can get for deducting net interest and other financing costs.
This Corporate Interest Restriction only applies to individual companies or groups of companies that have net interest and financing costs of over £2 million in a 12-month period.
If your company’s or group’s net interest and financing costs are restricted, you should appoint a reporting company with a deadline of within 12 months of the end of the period of account. The reporting company must then submit a Corporate Interest Restriction return.
If your net interest and financing costs are less than £2 million
Your company or group does not need to submit a Corporate Interest Restriction return. However, you must keep documents that show that your company or group will not deduct more than £2 million in net interest and financing costs in that period of account.
You can still appoint a reporting company, this company must then submit an abbreviated return. To reduce a future interest restriction, you can carry forward unused interest allowance for up to 5 years by replacing the abbreviated return with a full return for that period of account.
If your net interest and financing costs are more than £2 million
You must work out your company’s or group’s ‘interest allowance’. This is the maximum amount of net interest and financing costs your company or group can deduct in a period of account.
You can use the ‘fixed ratio method’ or the ‘group ratio method’. Use the method that gives you the largest allowance.
You must keep records of your calculation.
If your company’s or group’s net interest and financing costs are restricted, you should normally appoint a reporting company within 12 months of the end of the period of account unless you have previously appointed one. The reporting company must then submit a full Corporate Interest Restriction return.
Fixed ratio method
Using the fixed ratio method, the interest allowance is the lower of:
- 30% of the company’s or group’s UK taxable profits before interest, taxes, capital allowances and some other tax reliefs
- the company’s or group’s worldwide net interest expense
Group ratio method
To use this method, you must:
- appoint a reporting company
- elect to use the method in a Corporate Interest Restriction return
Using the group ratio method, the interest allowance is the lower of:
- the ratio of the company’s or group’s worldwide net interest expense owed to unrelated parties, to the company’s or group’s overall profit before tax, interest, depreciation and amortisation multiplied by the company’s or group’s taxable UK profits before interest and capital allowances
- the company’s or group’s worldwide net interest expense owed to unrelated parties
If your interest deductions are not restricted
You can appoint a reporting company, which must then submit an abbreviated return. If you replace the abbreviated return with a full return for that period of account, you can carry forward unused interest allowance for up to 5 years to reduce a future interest restriction.
Appoint a reporting company
Individual companies and groups can appoint a reporting company. Your reporting company will be responsible for submitting your company’s or group’s Corporate Interest Restriction return. The reporting company must be:
- liable to UK Corporation Tax
- non-dormant
- authorised by at least 50% of the group’s non-dormant companies (which are liable for UK Corporation Tax) to be appointed as the reporting company
When you have appointed a reporting company, you must submit a Corporate Interest Restriction return for every period of account, including when there’s no interest restriction. If you revoke the appointment of a reporting company and do not have an interest restriction, you will not have to submit a return.
If you do not appoint a reporting company, HMRC might appoint one for you.
If you’ve missed the deadline for appointing a reporting company
If you’ve missed the deadline and you now wish to go ahead, for example, to carry forward unused interest allowance following an unforeseen change of circumstances, then HMRC may appoint a reporting company for you.
You’ll need to do the following:
- tell us why you did not appoint a reporting company within the time limit
- give the reasons you’re asking HMRC to appoint the reporting company — for example, this could be due to coronavirus (COVID-19)
We will not routinely appoint just because the time limit was missed
We will consider doing so where there is an unforeseeable change in circumstances or other reason outside your control.
If you want to ask HMRC to appoint a reporting company you can either email:
- your customer compliance manager
- msbcorporateinterest.restrictionmailbox@hmrc.gov.uk — If you do not have a customer compliance manager
Tell HMRC about the appointment of your reporting company
Tell HMRC about the appointment of your reporting company
You must submit your reporting company appointment electronically either by:
- using commercial software
- completing the online form
You must also use the above methods if you need to revoke a reporting company appointment.
Using commercial software
To appoint a reporting company using commercial software, you will need a Government Gateway user ID and password. If you are an agent submitting the appointment on behalf of your client, you can use your own Gateway user ID and password.
If you do not have a user ID, you can create one when you use the service. HMRC will only accept submissions from organisations that have a Corporation Tax account with us.
Check ‘Commercial software suppliers for Corporation Tax’ for a list of commercial software suppliers for Interest Restriction Returns.
Using the online form
To appoint a reporting company:
- Fill in the template.
- Complete the online form and upload the template.
To use the online service, you need a Government Gateway user ID and password. If you do not have a user ID, you can create one when you use the service.
You only need to appoint a reporting company once.
Revoke the appointment of a reporting company
To change your reporting company, you’ll need to tell HMRC you want to revoke your current reporting company and appoint a new one. This needs to be authorised by at least 50% of the group’s non-dormant companies (that are liable for UK Corporation Tax).
Submit a return
Your reporting company must submit a return within 12 months of the end of the reporting period the return is for.
Find out how to submit a full or abbreviated Corporate Interest Restriction return.
You must submit your Corporate Interest Restriction return electronically by either:
- using commercial software
- completing the online form
This applies to both original and revised returns.
Check ‘Commercial software suppliers for Corporation Tax’ for a list of commercial software suppliers for Interest Restriction Returns.
From 1 October 2022 you’ll need to give us more information on a Corporate Interest Restriction return.
You’ll need to tell us:
- the country of incorporation for the larger parent company (ultimate parent) — if they do not have a Corporation Tax unique tax reference number (UTR)
- the legal entity identifier for the larger parent company (ultimate parent)
- if there are any companies within the group who have made a qualifying infrastructure company election — which has effect within the period of account
- the self assessment unique tax reference numbers of any UK partnerships where the group has made an interest allowance (consolidated partnerships) election
- the adjusted net group-interest expense for the period, even if the group ratio is used
Make an election
Elections let you choose a particular way of having your company’s or group’s tax treated, like choosing to use the group ratio method to work out your interest allowance. You should make elections in a Corporate Interest Restriction return.
If you need to make an election, but cannot do it in a return, send the details of the election to your Customer Compliance Manager.
Or, post the details of the election to:
Corporation Tax Services
HM Revenue and Customs
BX9 1AX
You should mention Corporate Interest Restriction in your election to help HMRC direct your letter to the correct team.
Penalties
If your company or group does not submit a Corporate Interest Restriction return when it should, it might have to pay a fixed penalty of:
- £500 if the return is up to 3 months late
- £1,000 if the return is more than 3 months late
If you submit an inaccurate Corporate Interest Restriction return, your company or group might have to pay a penalty of up to 100% of the extra tax (or lower tax relief) owed in the corrected return.
The amount of penalty you’ll have to pay will depend on the type of error and when you told HMRC about it. The penalty might be less if you tell HMRC about your error before they discover it.
Get more information
For help or more information, you can:
- find more information about Corporate Interest Restriction in HMRC’s Corporate Finance Manual
- contact your Customer Compliance Manager
- email msbcorporateinterest.restrictionmailbox@hmrc.gov.uk — do not email returns
Last updated 31 August 2022 + show all updates
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We have added guidance on what you can do if you've missed the deadline for appointing a reporting company. We have also added guidance on what you’ll need to give us on a Corporate Interest Restriction return from 1 October 2022.
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The process on how to tell HMRC about the appointment of your reporting company and submitting a return has been updated. You must now do this electronically using commercial software or by completing our online form and template.
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Changes to the process to follow if you have missed the deadline for appointing a reporting company.
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HMRC will accept elections by email while temporary measures are in place to stop the spread of coronavirus (COVID-19).
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The timescale on when you should appoint a reporting company has been updated.
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The address to send Corporate Interest Restriction elections to has been updated.
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This guide has been updated to include more information about how to work out your company's or group's interest allowance.
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The postal address to send elections outside of the interest restriction return has changed.
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Guidance on how to submit full or abbreviated Corporate interest restriction Returns has been added.
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The Google worksheet for appointment of a reporting company has been replaced with an Excel worksheet.
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Updated with information on how to make an election outside of a return.
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This guidance has been updated to include details of how to appoint a reporting company.
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First published.