Draft regulations (the Corporate Interest Restriction (Electronic Communications) Regulations 2022) provide that certain notices and returns relating to the corporate interest restriction (CIR) must be sent via an approved method of electronic communication from 1 September 2022 (including for documents relating to periods of account ending before that date).
The explanatory notes to the draft regs explain that while HMRC has previously accepted CIR documents through a number of different channels, this has led to duplication of effort for customers unsure of the best submission route, inefficiencies for HMRC in processing the documents, and an increased risk that errors in the documents will remain undetected.
The draft regs therefore mandate the use of electronic delivery by HMRC approved methods for the following documents:
a notice appointing a reporting company;
a notice revoking the appointment of a reporting company;
an interest restriction return; and
a revised interest restriction return.
Further, a draft HMRC notice sets out details of additional information that will be required on a corporate interest restriction return from late 2022. This includes:
information relating to the ultimate parent of the worldwide group;
details of companies within the worldwide group that have made a qualifying infrastructure election under TIOPA 2010 s 433 within the return period; and
the self-assessment unique taxpayer references of UK partnerships in respect of which the group has made an interest allowance election under TIOPA 2010 Sch 7A para 18; and
where a full interest restriction return is submitted in accordance with TIOPA 2010 Sch 7A para 20(3), the adjusted net group-interest expense of the worldwide group for the return period.
Draft regulations (the Corporate Interest Restriction (Electronic Communications) Regulations 2022) provide that certain notices and returns relating to the corporate interest restriction (CIR) must be sent via an approved method of electronic communication from 1 September 2022 (including for documents relating to periods of account ending before that date).
The explanatory notes to the draft regs explain that while HMRC has previously accepted CIR documents through a number of different channels, this has led to duplication of effort for customers unsure of the best submission route, inefficiencies for HMRC in processing the documents, and an increased risk that errors in the documents will remain undetected.
The draft regs therefore mandate the use of electronic delivery by HMRC approved methods for the following documents:
a notice appointing a reporting company;
a notice revoking the appointment of a reporting company;
an interest restriction return; and
a revised interest restriction return.
Further, a draft HMRC notice sets out details of additional information that will be required on a corporate interest restriction return from late 2022. This includes:
information relating to the ultimate parent of the worldwide group;
details of companies within the worldwide group that have made a qualifying infrastructure election under TIOPA 2010 s 433 within the return period; and
the self-assessment unique taxpayer references of UK partnerships in respect of which the group has made an interest allowance election under TIOPA 2010 Sch 7A para 18; and
where a full interest restriction return is submitted in accordance with TIOPA 2010 Sch 7A para 20(3), the adjusted net group-interest expense of the worldwide group for the return period.
