CFM98950 - Interest restriction: administration: record retention and information powers: meaning of "checking an interest restriction return"

TIOPA10/SCH7A/PARA67

Checking an interest restriction includes:

• Determining whether or not an interest return should be submitted for a period of account of a worldwide group
• Determining whether interest restrictions are due, and quantifying them
• Determining the membership of a group, including which entities are UK group companies
• Determining any other question relative to the operation of TIOPA 2010/Part 10 in relation to a return or anything that should have been included in a return.

This restricts the matters to those connected with the interest restriction legislation. By way of contrast, the scope of FA 2008/Sch. 36 is wider, encompassing checking the taxpayer’s tax position - para. 1(1) thereof.