SP1/12 ADVANCE THIN CAPITALISATION AGREEMENTS UNDER THE APA LEGISLATION
[30 January 2012]
1. This Statement of Practice replaces SP 04/07, which introduced the practice of providing Advance Thin Capitalisation Agreements (ATCAs) under the Advance Pricing Agreement legislation. It updates the legislative references, largely to the Taxation (International & Other Provisions) Act (TIOPA) 2010, and reflects HMRC’s current practice.
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