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HMRC internal manual

Corporate Finance Manual

Debt cap: appointment of the authorised company: outline

This guidance applies to worldwide group periods of account ending before or straddling 1 April 2017.

An overview of appointing an authorised company as the reporting body

Statements of allocated disallowances and statements of allocated exemptions have to be made by a reporting body. The reporting body can be an authorised company appointed by the other companies within TIOPA10/PT7/CH3 and CH4. Whether the authorised company is appointed to submit statements of allocated disallowances or statements of allocated exemptions, the basic procedures are the same.

A group is not obliged to appoint an authorised company. But if it does not do so, the reporting body becomes the relevant group companies (for a statement of allocated disallowances) or the UK group companies (for a statement of allocated exemptions), acting jointly. The onus to submit the necessary statements falls on these reporting bodies - a group cannot escape the statutory obligation to submit statements by not appointing an authorised company.

An authorised company for a statement of allocated disallowances can only be appointed by relevant group companies, whereas it is the UK group companies that appoint an authorised company for the statement of allocated exemptions. For further guidance on relevant group companies see CFM90240 and for further guidance on UK group companies see CFM90250.

This section of guidance describes the procedures for appointing an authorised company, or revoking an appointment. The legislation in TIOPA10/PT7/CH3 and CH 4 is supplemented by more detailed rules in The Corporation Tax (Financing Costs and Income) Regulations 2009 (SI 2009/3173).