Taxation (International and Other Provisions) Act 2010 section 20

Required contents of interest restriction return: full returns and abbreviated returns

Section 20 sets out what must be included in an interest restriction return, distinguishing between a full return and an abbreviated return depending on whether the group is subject to interest restrictions and whether an abbreviated return election is in place.

  • A full return is required when the group is subject to interest restrictions, or when it is not subject to restrictions but no abbreviated return election is in effect โ€” it must include parent entity details, the return period, UK group company details, a statement of calculations, any restriction or reactivation allocations, and a declaration of correctness.
  • An abbreviated return may be filed when the group is not subject to interest restrictions and an abbreviated return election is in effect โ€” it need only confirm the absence of restrictions, identify the parent and UK group companies, and include the declaration of correctness.
  • HMRC may require additional specified information to be included in either type of return, with the details set out in a published notice which may vary for different purposes.
  • Where the ultimate parent is a deemed parent due to stapled entities or business combinations, the return must name and provide the Unique Taxpayer Reference for each of the relevant entities rather than a single parent.

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