Thin capitalisation: the UK reforms
December 19, 2007
Deloitte UK analyses the HMRC’s statement of practice on advance thin capitalisation agreements. Michael Gordon-Brown and Ian Clarke report
Earlier this year HM Revenue & Customs (HMRC) announced that it was changing the way it deals with thin capitalisation and transfer pricing matters associated with financing. It immediately stopped linking this to treaty withholding tax clearance applications, and announced a consultation on the use of advanced pricing agreement legislation, but with some relaxations to be set out in a new statement of practice (SP).
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