³ÉÈËÓ°Òô

Corporate interest restriction ― fixed ratio method

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Corporate interest restriction ― fixed ratio method

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

The fixed ratio method is the default method of limiting the deduction available under the corporate interest restriction (CIR) rules. For a general overview of the regime, see the Corporate interest restriction ― overview guidance note.

The fixed ratio method restricts the deductibility of interest based on the lower of two figures. These are:

  1. •

    a proportion (30%) of the aggregate tax-EBITDA of the companies in the CIR worldwide group which are subject to UK corporation tax, and

  2. •

    the fixed ratio debt cap, which is generally the adjusted net group interest expense (ANGIE)

An alternative method for calculating the restriction, known as the group ratio method, is available by election only. See the Corporate interest restriction ― group ratio method guidance note for details.

The fixed ratio method is so-called as it uses a fixed ratio (30%) of tax-EBITDA.

The fixed ratio debt cap looks at the external net group interest expense (sometimes referred to by the acronym NGIE) of the worldwide group based on the consolidated P&L. This is then

Access this article and thousands of others like it
free for 7 days with a trial of Tolley+™ Guidance.

Powered by
  • 16 Apr 2024 10:01

Popular Articles

Company cars

Company carsIntroductionCompany cars are one of the most common taxable benefits. The rules for calculating the benefit are complex, and the reporting requirements are more onerous than most benefits. Company cars are covered by very specific legislation. Detailed guidance on each of the following

14 Jul 2020 11:15 | Produced by Tolley Read more Read more

Payments to trust beneficiaries

Payments to trust beneficiariesThis guidance note considers the trustees powers to make payments and whether the payment made is income or capital.This guidance note is designed to give outline and background for accountants and tax advisers who deal with clients establishing trusts. It is not

14 Jul 2020 12:52 | Produced by Tolley Read more Read more

Payments on account (POA)

Payments on account (POA)This guidance note provides and overview of the payments on account regime (POA). More in depth commentary can be found in De Voil Indirect Tax Service V5.110.What are payments on account?VAT registered businesses with an annual VAT liability of more than £2.3m are required

14 Jul 2020 12:52 | Produced by Tolley Read more Read more