Since 2007, it has been possible for advance thin capitalisation agreements (ATCAs) to be made under the APA legislation (see ¶774-895). However, it should be noted that although ATCAs and APAs are based on the same statutory provisions, separate processes are in place for the securing of an agreement. HMRC guidance on the process for entering into an ATCA is given in Statement of Practice SP1/2012 (which replaced SP4/2007 largely to update the legislative references). A model agreement can be found on the HMRC website at www.hmrc.gov.uk/cnr/draft-atca-v1.pdf.

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