HMRC has issued Directions, made under the power in reg 2(2) of the Corporate Interest Restriction (Electronic Communications) Regulations, SI 2022/770, setting out the approved electronic filing methods which must be used from 1 September 2022 to submit the following:
appointment of a reporting company;
revocation of an existing reporting company;
interest restriction returns; and
revised interest restriction returns.
The directions say that the information must be submitted either using commercial software designed for the particular purpose (and listed on the CIR pages on gov.uk), or using the filing product provided by HMRC on gov.uk. It is not currently clear if or where that software is listed or which filing product HMRC has in mind. For example, HMRC guidance links to its online tool for appointing a reporting company, but this would not be the ‘filing product’ for other purposes.
HMRC’s list of ‘application programming interfaces’ (usually know as APIs) for CIR are available on its developer pages, and its template for appointing a reporting company online is linked to from HMRC’s main interest restriction guidance.
Additional information requirements
HMRC has published a notice setting out additional information requirements for interest restriction returns filed on or after 1 October 2022.
The basic requirements for interest restriction returns are set out in TIOPA 2010 Sch 7A. The ‘required contents’ of returns under para 20 of the schedule include various details – for example, the name and UTR of the ultimate parent of the worldwide group and of UK group companies, the return period, and a statement of calculations.
Paragraph 20 also empowers HMRC to add ‘other specified information’ which must be included in returns.
HMRC has published a notice, which has the force of law under para 20, setting out the following additional information which must be included in interest restriction returns filed with HMRC on or after 1 October 2022:
country of incorporation of the ultimate parent of the worldwide group where it does not have a UTR;
legal entity identifier of the ultimate parent of the worldwide group where it has one;
companies within the worldwide group which have made a qualifying infrastructure election under TIOPA 2010 s 433 that has effect at any time within the return period;
self-assessment UTRs 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 under para 20(3), the adjusted net group-interest expense of the worldwide group for the return period.
HMRC has issued Directions, made under the power in reg 2(2) of the Corporate Interest Restriction (Electronic Communications) Regulations, SI 2022/770, setting out the approved electronic filing methods which must be used from 1 September 2022 to submit the following:
appointment of a reporting company;
revocation of an existing reporting company;
interest restriction returns; and
revised interest restriction returns.
The directions say that the information must be submitted either using commercial software designed for the particular purpose (and listed on the CIR pages on gov.uk), or using the filing product provided by HMRC on gov.uk. It is not currently clear if or where that software is listed or which filing product HMRC has in mind. For example, HMRC guidance links to its online tool for appointing a reporting company, but this would not be the ‘filing product’ for other purposes.
HMRC’s list of ‘application programming interfaces’ (usually know as APIs) for CIR are available on its developer pages, and its template for appointing a reporting company online is linked to from HMRC’s main interest restriction guidance.
Additional information requirements
HMRC has published a notice setting out additional information requirements for interest restriction returns filed on or after 1 October 2022.
The basic requirements for interest restriction returns are set out in TIOPA 2010 Sch 7A. The ‘required contents’ of returns under para 20 of the schedule include various details – for example, the name and UTR of the ultimate parent of the worldwide group and of UK group companies, the return period, and a statement of calculations.
Paragraph 20 also empowers HMRC to add ‘other specified information’ which must be included in returns.
HMRC has published a notice, which has the force of law under para 20, setting out the following additional information which must be included in interest restriction returns filed with HMRC on or after 1 October 2022:
country of incorporation of the ultimate parent of the worldwide group where it does not have a UTR;
legal entity identifier of the ultimate parent of the worldwide group where it has one;
companies within the worldwide group which have made a qualifying infrastructure election under TIOPA 2010 s 433 that has effect at any time within the return period;
self-assessment UTRs 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 under para 20(3), the adjusted net group-interest expense of the worldwide group for the return period.
