The rules comprising the corporate interest restriction (CIR) were introduced with effect from 1 April 2017 in order to tackle erosion of the UK tax base through the use of interest deductions.
The main rules are found in Part 10 of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010), with related administrative provisions being found in TIOPA 2010, Sch 7A. HMRC's published guidance on the CIR can be found in its Corporate Finance Manual, starting at CFM95000.
The CIR rules are lengthy and complex. Many of the key operative provisions are heavily calculations-based, and use multiple defined terms. For an introduction to the CIR rules and a more general overview of how the CIR works (including the background to its introduction), see Practice Note: Corporate interest restriction—quick guide.
For quick access to the meanings of key terms and concepts used throughout the CIR legislation, see Practice Note: Corporate interest restriction—glossary of key terms.
The CIR rules place a limit on the amount of interest and certain other financing costs that large businesses
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