Steve Edge Slaughter and May looks at the consequences of HMRC's recent press release on a breach of the financial covenants set by an Advance Thin Capitalisation Agreement
HMRC has recently put out a release (to be found at http://www.hmrc.gov.uk/cap/atca.htm) dealing with the consequences of a breach of the financial covenants set by an advance thin capitalisation agreement (ATCA). This raises some interesting issues.
More art than science
Like transfer pricing thin capitalisation raises difficult points for tax authorities around the world. Trying to work out the right amount of debt that each jurisdiction should bear on an inbound investment basis is definitely more art than science.
Unlike many other...
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Steve Edge Slaughter and May looks at the consequences of HMRC's recent press release on a breach of the financial covenants set by an Advance Thin Capitalisation Agreement
HMRC has recently put out a release (to be found at http://www.hmrc.gov.uk/cap/atca.htm) dealing with the consequences of a breach of the financial covenants set by an advance thin capitalisation agreement (ATCA). This raises some interesting issues.
More art than science
Like transfer pricing thin capitalisation raises difficult points for tax authorities around the world. Trying to work out the right amount of debt that each jurisdiction should bear on an inbound investment basis is definitely more art than science.
Unlike many other...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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