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What is Angie CIR?

The second limb of the fixed ratio method for the corporate interest restriction (CIR), the fixed ratio debt cap, limits interest relief by reference to an amount equalling the 'adjusted net group-interest expense' (ANGIE) of the group1.

What is CIR tax?

The CIR rule applies after other tax adjustments. The starting position for calculating tax-EBITDA is a company's Profit Chargeable to Corporation Tax after almost all tax adjustments \u2013 the main exception being R&D relief. Interest, capital allowances and intangible fixed asset allowances are added back.

What is the purpose of the corporate interest restriction?

When you work out how much UK Corporation Tax your company or group has to pay, there's a limit (known as a Corporate Interest Restriction). This limits the amount of tax relief you can get for deducting net interest and other financing costs.

What is the fixed ratio debt cap?

The fixed ratio debt cap is the sum of: \u2022 the adjusted net group-interest expense (¶718-580) of the worldwide group for the period; and. \u2022 the excess debt cap (below) of the group for the immediately preceding period (if any) (TIOPA 2010, s. 400(1)).

What is unused interest?

Unused interest allowance is carried forward at group level (defined by the identity of the ultimate parent) and can be used in a subsequent period for up to five years. Unused interest allowance can only be carried forward where a full interest restriction return has been filed.

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