The Corporate Interest Restriction (Electronic Communications) (Amendment) Regulations 2026

Published: Thu 26th Mar 26

These Regulations, enacted by His Majesty's Revenue and Customs (HMRC), amend the Corporate Interest Restriction (Electronic Communications) Regulations 2022 to align them with changes made to Schedule 7A of the Taxation (International and Other Provisions) Act 2010 by the Finance Act 2026, specifically removing requirements for filing appointments or revocations of reporting companies via formal notice, effective for accounting periods ending on or after March 31, 2026.

Arguments For

The amendments streamline the administrative process for the corporate interest restriction (CIR) by aligning electronic communication requirements with recent legislative changes to the Taxation (International and Other Provisions) Act 2010 (Schedule 7A).
Removing outdated requirements for appointments or revocations of reporting companies to be submitted via formal 'notice' simplifies compliance for worldwide groups, as electronic methods are now preferred or mandated elsewhere.
The regulations ensure that the existing framework for handling CIR information electronically remains legally current and effective for accounting periods ending on or after March 31, 2026.

Arguments Against

Any changes to compliance procedures, even minor amendments, introduce a risk of confusion among businesses regarding which specific documentation (notices versus standard electronic submissions) must now adhere to the amended rules.
While intended to streamline procedures, the amendment relies on parallel changes in primary legislation (Finance Act 2026) and secondary regulations, creating complexity in tracing the full legal basis for compliance.
The regulation removes specific requirements regarding proof of delivery for 'notice or', which might unintentionally weaken accountability mechanisms for official correspondence related to the CIR if alternative proof methods are not explicitly detailed elsewhere.

STATUTORY INSTRUMENTS

2026 No. 352

CORPORATION TAX

The Corporate Interest Restriction (Electronic Communications) (Amendment) Regulations 2026

Made - - - -

25th March 2026

Laid before the House of

Commons - - - -

26th March 2026

Coming into force - -

1st April 2026

This formatting identifies the document as a Statutory Instrument (SI) numbered 2026 No. 352, specifically concerning Corporation Tax.

It also records the key legislative dates: made on March 25, 2026, laid before Parliament on March 26, 2026, and coming into force on April 1, 2026.

The Commissioners for His Majesty's Revenue and Customs make these Regulations in exercise of the powers conferred by sections 135(1), (2)(a) and (e), (3)(a) and 136 of the Finance Act 2002( 1 ) and now exercisable by them( 2 ) and paragraph 3 of Schedule 7A to the Taxation (International and Other Provisions) Act 2010( 3 ).

HMRC issues these Regulations using powers granted under specific sections of the Finance Act 2002 and paragraph 3 of Schedule 7A of the Taxation (International and Other Provisions) Act 2010.

These citations confirm the legal authority under which HMRC is amending previous regulations.

Citation, commencement and effect

-(1) These Regulations may be cited as the Corporate Interest Restriction (Electronic Communications) (Amendment) Regulations 2026 and come into force on 1st April 2026.

(2) These Regulations have effect for periods of account( 4 ) ending on or after 31st March 2026.

Regulation 1 establishes the official short title for this instrument and confirms its commencement date as April 1, 2026.

Subsection (2) specifies the retroactive application, stating the amendments apply to any accounting periods that conclude on or after March 31, 2026.

Amendment of the Corporate Interest Restriction (Electronic Communications) Regulations 2022

-(1) The Corporate Interest Restriction (Electronic Communications) Regulations 2022( 5 ) are amended as follows.

(2) In regulation 2 (requirement to submit information using electronic communications)-

(a) in paragraph (1)-
(i) omit sub-paragraphs (a) and (b);

( 1 ) 2002 c. 23; section 135 was amended by paragraphs 94 and 95 of Schedule 4 to the Commissioners for Revenue and Customs Act 2005 (c. 11), section 93(1) to (3) of the Finance Act 2007 (c. 11), and S.I. 2011/1043.

( 2 ) The functions of the Commissioners of Inland Revenue under section 136 of the Finance Act 2002 were transferred to the Commissioners for His Majesty's Revenue and Customs by section 5(1) of the Commissioners for Revenue and Customs Act 2005. Section 50(1) of that Act provides that, in so far as is appropriate in consequence of section 5, a reference, howsoever expressed, to the Commissioners of Inland Revenue is to be taken as a reference to the Commissioners for His Majesty's Revenue and Customs.

( 3 ) 2010 c. 8; Schedule 7A was inserted by paragraph 2 of Schedule 5 to the Finance (No. 2) Act 2017 (c. 32).

( 4 ) See section 480 of the Taxation (International and Other Provisions) Act 2010 for the definition of 'period of account'.

( 5 ) S.I. 2022/770.

Regulation 2 introduces the amendments to the existing 2022 Regulations governing how Corporate Interest Restriction (CIR) information must be submitted electronically.

Specifically, paragraph (2)(a)(i) removes sub-paragraphs (a) and (b) from regulation 2(1) of the 2022 instrument concerning the requirements for submitting information electronically.

(ii) in sub-paragraph (c), for 'that Schedule' substitute 'Schedule 7A to the Taxation (International and Other Provisions) Act 2010';
(b) omit paragraph (3).

Sub-paragraph (ii) updates a reference within the 2022 Regulations, substituting 'that Schedule' with the full name of 'Schedule 7A to the Taxation (International and Other Provisions) Act 2010.' Additionally, paragraph (3) of regulation 2 in the 2022 Regulations is entirely removed.

(3) In regulation 3 (proof of delivery of information)-
(a) in paragraph (1), omit 'notice or';
(b) in paragraph (2), omit 'notice or'.

Regulation 3 concerns the rules for proving the delivery of CIR information.

It mandates the removal of the phrase 'notice or' from paragraph (1) and paragraph (2) of regulation 3 in the 2022 Regulations, suggesting that the procedure for confirming delivery no longer hinges specifically on formal 'notices'.

25th March 2026

Daljit Rehal Jonathan Athow Two of the Commissioners for His Majesty's Revenue and Customs

This concludes the instrument, showing that the two Commissioners for HMRC, Daljit Rehal and Jonathan Athow, formally executed the instrument on March 25, 2026.

EXPLANATORY NOTE

(This note is not part of the Regulations)

These Regulations amend the Corporate Interest Restriction (Electronic Communications) Regulations 2022 ('the 2022 Regulations'). The 2022 Regulations make provision for certain notices and returns relating to the corporate interest restriction to be sent to HMRC via an approved method of electronic communication. These Regulations make consequential amendments to the administration of the corporate interest restriction following the amendments to Schedule 7A to the Taxation (International and Other Provisions) Act 2010 made by section 61 of Part 1 of the Finance Act 2026 (c. 11). Those amendments remove the requirement for a worldwide group to make appointments or revocations of their reporting company by notice to His Majesty's Revenue and Customs with effect for periods of account ending on or after 31st March 2026.

A Tax Information and Impact Note covering this instrument was published on 26th November 2025 alongside the Budget 2025 and is available on the website at https://www.gov.uk/government/ collections/tax-information-and-impact-notes-tiins. It remains an accurate summary of the impacts that apply to this instrument.

The Explanatory Note clarifies that the purpose is to amend the 2022 Regulations, which govern the electronic submission of CIR returns and notices to HMRC. The amendments are consequential to Section 61 of the Finance Act 2026, which removed the statutory requirement for worldwide groups to submit appointments or revocations of their reporting company via formal notice. It also directs readers to an associated Tax Information and Impact Note.

View Source

Education Technology

The Power to Award Degrees etc. (Spurgeon’s College) (Revocation) Order 2026

Thu 9th Apr 26

The Office for Students revoked the 2022 and 2025 Orders granting degree awarding powers to Spurgeon's College because the institution ceased to be a registered higher education provider.

Economy Finance

The Social Security Contributions (Umbrella Companies) Regulations 2026

Wed 1st Apr 26

The Order amended the Financial Promotion Order 2005, modifying regulations governing the promotion of financial services and investments within the UK.

Energy Environment Finance Health and Social Care Labour

The Warm Home Discount (England and Wales) Regulations 2026

Tue 31st Mar 26

The Warm Home Discount (England and Wales) Regulations 2026 were made to continue the fuel poverty reduction scheme until 2031, defining supplier obligations, rebate mechanisms, and spending requirements for energy efficiency measures.

Culture and Sport Finance Justice

The Grants to the Churches Conservation Trust Order 2026

Fri 27th Mar 26

The Order specified the funding period from April 2026 to March 2029 and set the maximum aggregate grant amount at £9,531,000 for the Churches Conservation Trust, revoking the 2025 Order.