Market leading insight for tax experts
View online issue

Advance Thin Cap Agreements

Speed read

The absence of thin cap safe harbours means that companies seeking comfort that their UK interest expense will be deductible need to agree an ATCA with HMRC. This does not offer complete protection (as unallowable purpose tests can still apply to disallow deductions and an ATCA does not oust the worldwide debt cap provisions); nevertheless the ability to reach a tailored agreement with HMRC reflecting the particular business’s or group’s circumstances generally makes the effort worthwhile and, for taxpayers prepared to engage in such discussions, can outweigh the initial attraction of a ‘one size fits all’ test.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.