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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.
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.
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.
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)).
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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ANGIE is calculated by making certain upward and downward adjustments to NGIE. Where ANGIE is negative, the group as a whole is not in a net-interest expense position for CIR purposes, but, rather, is in a net-interest income position.
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.
Interest reactivation The company is allowed to carry it forward indefinitely to be potentially reactivated in future periods. If for any period the group's interest allowance exceeds its aggregate net tax-interest expense then an interest reactivation cap will arise.
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.
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)).

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