½Û×ÓÊÓÆµ

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

Continue reading the full document
To gain access to additional expert tax guidance, workflow tools, generative tax AI, and tax research, register for a free trial of Tolley+â„¢
Powered by
  • 06 Jun 2025 06:40

Popular Articles

Taxation of loan relationships

Taxation of loan relationshipsThe vast majority of companies will have loan relationships and so will need to consider how they are taxed under the loan relationship rules. There are also specific provisions dealing with relevant non-lending relationships and other deemed loan relationships.

14 Jul 2020 13:48 | Produced by Tolley Read more Read more

Loans written off

Loans written offCompanies sometimes provide directors, employees or shareholders with low interest or interest-free loans either as part of the reward package or on special occasions to help the individual meet significant expenditure. The employment income implications of these loans are discussed

14 Jul 2020 12:11 | Produced by Tolley Read more Read more

Temporary differences

Temporary differencesCalculation of temporary differencesThe temporary difference arising in respect of an asset or liability is calculated by comparing the carrying value of that asset or liability with its tax base.IAS 12 uses the concept of taxable or deductible temporary differences. Whether a

14 Jul 2020 13:49 | Produced by Tolley in association with Malcolm Greenbaum Read more Read more