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Thin Capitalisation

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 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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