CFM98477 - CFM98477 - Interest restriction: administration: reporting requirements: appointment of a reporting company by group
The following sets out the position for periods of account ending on or after 31 March 2024.
TIOPA10/SCH7A/PARAS1A
CIR allows groups to retrospectively appoint a reporting company after the filing deadline in certain circumstances. This is to avoid the difficulties that could otherwise arise where an interest restriction return is submitted without a valid reporting company having been appointed.
Conditions
Retrospective appointment of a reporting company is permitted where a company has purported to submit an interest restriction return to HMRC for a period of account (i.e. it has sent a return to HMRC, but the return is invalid due to the company not being validly appointed as the reporting company for the group).
Effect
In these circumstances, a member of the group may appoint the company identified on the return as the reporting company for the period of account. All of the other conditions for making an appointment in PARA1 still need to be met. For periods ending on/after 31 March 2026 there is no need for notification to be made to HMRC, the group should just keep a record.
The appointment is then treated as having been made immediately before the submission of the first return filed for the period of account. As a result, this addresses the issue that no reporting company had been appointed at the time the return was actually submitted.
Note that for periods ending on or after 31 March 2024 but before 31 March 2026, the group is still required to notify HMRC of the reporting company appointment. Where this is a retrospective appointment (made more than 12 months after the end of the period), the group will therefore need to first submit the interest restriction return, then notify HMRC of the retrospective appointment (using either the online form or commercial software).
Further guidance
Overview of reporting company appointments, see CFM98470.
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