How does the UK CIR 30% EBITDA rule work?

The UK CIR disallows UK group net interest expense exceeding 30% of aggregate UK tax-EBITDA. An alternative group ratio rule allows deduction up to the worldwide group's net interest/EBITDA ratio if higher than 30%. Disallowed amounts carry forward indefinitely.

What is the US Section 163(j) limit?

163(j) caps business interest expense deductions at 30% of adjusted taxable income (ATI). Pre-2022, ATI was EBITDA; from 2022, it is EBIT (depreciation no longer added back), significantly tightening the limit for capital-intensive businesses.

Interest Deduction Limitation Ratio EBITDA% Calculator

Calculate net interest expense deduction limit under OECD BEPS Action 4 rule: 30% of tax-EBITDA. Applies to UK CIR, EU ATAD, and US 163(j) limitation. Identifies disallowed interest carryforward.

Statute of Limitations

Incident / Event Date

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⚖ For informational purposes only. Not legal advice. Consult a licensed attorney for your specific situation.

How to Use

Enter the values for the scenario you are assessing. Calculate net interest expense deduction limit under OECD BEPS Action 4 rule: 30% of tax-EBITDA. Applies to UK CIR, EU ATAD, and US 163(j) limitation. Identifies disallowed interest carryforward. Use the interest deduction limitation result to inform your calculation.

Interest Deduction Limitation Ratio EBITDA% Calculator

Statute of Limitations

How to Use

Frequently Asked Questions

How does the UK CIR 30% EBITDA rule work?

What is the US Section 163(j) limit?