Daniel Head and Kashif Javed examine the practical challenges of the new CIR regime.
The new corporate interest restriction (CIR) regime, which is expected to be enacted retrospectively with effect from 1 April 2017, represents a significant restriction on groups’ ability to obtain UK tax relief for finance costs. It also poses significant practical challenges for UK groups, including in terms of: determining the scope of the CIR worldwide group; gathering and ‘cleansing’ all the data required in order to perform CIR calculations; making strategic decisions regarding elections, allocations and restructurings; and determining the impact on financial statements and tax instalments.
In a recent article for Tax Journal*, Daniel Head from our global transfer pricing services team and Kashif Javed from our international tax team take a look at some of the practical challenges of the new regime, including the technical operation of the regime and its impact on other areas of corporate taxation.
Please do get in touch with Daniel, Kashif or your regular KPMG contact to explore how KPMG can assist you with understanding the impact of the new rules on your business.
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* First published in Tax Journal on 27 October 2017. Reproduced with permission.