The short answer is ‘possibly’. Where a group has been subject to an interest restriction in the past, and in a later period of account its interest expense falls below the amount that would be allowable in that period, there is the possibility to reactivate previously disallowed amounts.
Reactivation is not automatic and is not always available. The rules are, however, designed to eliminate unfair permanent disallowances that could otherwise arise from short term situations or fluctuations.
The rules around reactivation are complex. We are happy to discuss how these may impact your business, so please don’t hesitate to get in touch.