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HMRC internal manual

Corporate Finance Manual

From:
HM Revenue & Customs
Published:
16 April 2016
Updated:
5 August 2026 - See all updates

CFM98470 - Interest restriction: administration: reporting requirements: appointment of a reporting company by group: TIOPA10/SCH7A/PARAS1-3

TIOPA10/SCH7A/PARAS1-3

In most cases where the corporate interest restriction (CIR) may be applicable, a group will choose to appoint a reporting company. TIOPA10/SCH7A/PARA1 provides the mechanism for making an appointment.

The rules dealing with the appointment of reporting companies were significantly updated in Finance Act 2026. The majority of the changes apply for periods of accounting ending on or after 31 March 2026.

The guidance on the appointment of reporting companies has therefore been split across the following pages.

Appointments by groups:

  • For periods ending before 31 March 2026, see CFM98472
  • For periods ending on or after 31 March 2026, see CFM98475

Appointments by HMRC:

  • For periods ending before 31 March 2026, see CFM98480
  • For periods ending on or after 31 March 2026, see CFM98487

Outline of the Finance Act 2026 changes

The main change made by FA 2026 is to remove the time limit to appoint a reporting company, and remove the requirement for the appointment to be made ‘by notice’ to HMRC. Instead, businesses will be responsible for ensuring the reporting company has been appointed for a period, with details of the appointment disclosed in the interest restriction return. 

The following additional changes are also made:

  • businesses and HMRC will be able to appoint a reporting company retrospectively for a period where an interest restriction return is purported to have been submitted to HMRC, which will allow the return to be treated as having been validly made (see CFM98477)
  • reporting company appointments will need to be authorised by over 50% of the group (for previous periods, the legislation allows exactly 50% of the group, which could result in a ‘deadlock’)
  • reporting company appointments will no longer automatically rollover to later periods, so groups will need to ensure the reporting company is authorised by over 50% of the group for each period
  • the statutory obligation on reporting companies to file an interest restriction return will be removed, except in the limited circumstances where HMRC appoints a reporting company or a replacement reporting company (see CFM98520)
  • a new £1,000 penalty will apply where a business has not validly appointed a reporting company before submitting an interest restriction return — this will be subject to certain safeguards (see CFM99005)