Finance Act 2026 Simplifies Corporate Interest Restriction
HMRC introduced changes to the Corporate Interest Restriction (CIR) rules in Finance Act 2026, aimed at reducing compliance burden for multi-entity groups whilst maintaining anti-avoidance protections. These changes are now live and affect how groups manage interest deductions and earnings limits.
For Ltd companies with debt structures spanning multiple entities, understanding the updated CIR rules is essential. The changes simplify rule compliance and reduce the volume of documentation required, though the core interest deduction limitations remain in force.
Groups should review their current positions to ensure compliance with the updated rules and assess whether any prior-period adjustments may be required. Tax planning specialists and accountants advising multi-entity groups should consult the Finance Act 2026 technical notes and HMRC's updated CIR guidance.
The changes particularly affect groups with cross-border interest, transfer pricing considerations, or complex intra-group loan arrangements. Early action to assess exposure can prevent compliance breaches and identify planning opportunities under the new framework.