³ÉÈËÓ°Òô

The fixed ratio method is the default method of limiting the deduction available under the corporate interest restriction (CIR) rules. For a general overview of the regime, see the Corporate interest restriction ― overview guidance note.

The fixed ratio method restricts the deductibility of interest based on the lower of two figures. These are:

1. •

   a proportion (30%) of the aggregate tax-EBITDA of the companies in the CIR worldwide group which are subject to UK corporation tax, and

2. •

   the fixed ratio debt cap, which is generally the adjusted net group interest expense (ANGIE)

An alternative method for calculating the restriction, known as the group ratio method, is available by election only. See the Corporate interest restriction ― group ratio method guidance note for details.

The fixed ratio method is so-called as it uses a fixed ratio (30%) of tax-EBITDA.

The fixed ratio debt cap looks at the