CIR reporting-company appointments must be authorised for each period

Groups must authorise their corporate interest restriction (CIR) reporting company for each period ending on or after 31 March 2026GOV. Finance Act 2026 ends automatic rollover, removes the appointment time limit and removes separate notice to HMRC, while introducing a £1,000 penalty for submitting a return without a valid appointmentLegislation.

Appointment requires authorisation by “more than half of the eligible companies for that period”GOV; previously, “at least 50% of eligible companies” was sufficient. An eligible company must have been a UK group company during the periodLegislation and not dormant throughout itLegislation. Revocation also requires more than half. Keep appointment evidence and authority for each period; standing documents are acceptable. The reporting company must ensure eligible companies know it is their appointed reporting company for the periods concerned.

Group-appointed reporting companies no longer have a general obligation to file an interest restriction returnGOV. HMRC-appointed companies must still file; replacements must do so unless a return has already been submitted. Voluntary filing can preserve unused interest allowance. The filing date is 12 months after period-endGOV, or, for HMRC appointments, three months after appointment if laterGOV. Takeovers can extend filing dates; closure notices and determinations have separate return limits. Revised-return and enquiry responsibilities continue; individual company tax returns must still account for CIR disallowances.

For periods ending on or after 31 March 2024, a group can repair a return submitted without a valid appointment by appointing the submitting company, meeting the other appointment conditionsGOV. The appointment is treated as made immediately before the first returnGOV; this deemed timing does not apply for the purposes of the £1,000 penaltyLegislation. For periods ending before 31 March 2026, HMRC must still be notifiedGOV: submit the return first, then notify the retrospective appointment through the online form or commercial software.

The £1,000 penalty does not arise if the group appoints the company retrospectively within 18 months after period-endGOV. Liability also does not arise if the company notified HMRC of the failure without being prompted, or had a reasonable excuse, with appointment without unreasonable delay after the excuse ceasedGOV. HMRC has 12 months from subsequent appointment to assess it. Appeal is due within 30 days of notification; payment is due within 30 days of notification or, if appealed, final determination or withdrawal.

Late-return penalties remain £500 within three months after the filing date and £1,000 thereafter, subject to reasonable excuse and prompt filing once it ends. The assessment window now runs for 12 months from receipt of the return; where no return is received, the statutory window instead runs from the relevant filing date.

HMRC can appoint a reporting company where no return arrives within 18 months after period-endGOV, superseding a group appointment. Its normal four-year appointment limit can extend where a company-tax-return amount remains alterable. HMRC retains separate retrospective appointment powers. The non-filing ground for a revenue determination now concerns HMRC-appointed companies; defective submitted returns remain another ground.

For periods ending on or after 31 March 2026, consent is notified to the reporting company aloneGOV. Authorising appointment no longer automatically confers consenting statusLegislation. Returns must identify consent status. Non-consenting companies retain the pro-rata allocation cap. A non-consenting company may elect not to accept the allocated disallowance; it must then submit or amend its company tax returns to include its own pro-rata computation.

Additional return fields covering the reporting company’s name and UTR, each company’s authorisation and a declaration of eligibility and majority support await commencement regulations; the guidance does not treat them as already effective.

The amendments are in Finance Act 2026 section 61, which amends Schedule 7A to the Taxation (International and Other Provisions) Act 2010.