Other news in brief

Businesses that are required to submit Corporate Interest Restriction (CIR) returns are reminded that, from 1 September 2022, HMRC require the returns (revised or new) to be submitted electronically, either via their online portal (also known as the ‘G-form’ or ‘Government gateway’) or via a HMRC-approved tax software ‘Application Programming Interface’ (API) solution. In addition, on 25 August 2022, a Notice was published confirming additional information that must be included in any CIR return (revised or new) filed on or after 1 October 2022. The additional information required is: (i) the country of incorporation of the ultimate parent of the worldwide group where it does not have a Unique Taxpayer Reference (UTR); (ii) the Legal Entity Identifier of the ultimate parent of the worldwide group where it has one; (iii) a list of which companies within the worldwide group have made a qualifying infrastructure election under s.433 TIOPA 2010 that has effect at any time within the return period; (iv) the Self-Assessment UTRs of UK partnerships in respect of which the group has made an interest allowance (consolidated partnerships) election under paragraph 18 Schedule 7A TIOPA 2010; and (v) where the CIR return is a ‘full’ return (as opposed to an ‘abbreviated return’) it must now include a figure for the ‘adjusted net group-interest expense’ (ANGIE) of the worldwide group for the return period, irrespective of whether the worldwide group has made a group ratio election or, if the fixed ratio method applies, the debt cap is the limiting factor in the CIR calculation. The final item listed is likely to have the most significant computational impact in practice – if you need advice on this or any of the other changes please speak to your usual KPMG in the UK contact.

The Office of Tax Simplification (OTS) published its call for evidence for its review of hybrid and distance working on 31 August 2022 (see our Tax Matters Digest article of 8 August 2022 for coverage of the scope of the review). The call for evidence invites submissions in respect of both international and domestic aspects of hybrid and distance working, focusing on changes in practice and emerging trends, by 25 November 2022. The OTS expects to publish its findings in early 2023. We will publish further commentary on the OTS review and call for evidence in due course.

The OTS is currently looking to expand the independent membership of its Board, with the creation of two additional positions. More details about the two roles and how to apply can be found on the Cabinet Office website. The deadline for written applications is 25 September 2022.