HMRC has published revised guidance on making Advance Thin Capitalisation Agreement (ATCA) Applications. Despite dramatic changes in the world of corporate financing, HMRC’s revised guidance largely maintains its existing practice. This may reassure businesses which have an existing ATCA or are thinking of applying for one.
HMRC’s revised guidance on ATCA applications ie on agreements between HMRC and the taxpayer as to what constitutes an acceptable arm’s-length position concerning related party debt is contained in Statement of Practice SP 1/12 published on 3 February 2012 replacing SP 4/07. Readers may recall that around the time that SP 4/07 was published in the summer of 2007 the phrase ‘credit crunch’ was first being heard. Before then banks seemed...
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