Jeanette Zaman and Richard Jeens consider the case for negotiating advance thin capitalisation agreements with HMRC and whether the absence of safe harbours is a missed opportunity.
The benefits to a business of agreeing an advance thin capitalisation agreement (ATCA) with HMRC are clear. The intention is that the business or group can then plan its operations and investment over a number of years safe in the knowledge that within the agreed bounds set in the ATCA interest payable on its debt will be deductible for tax purposes. HMRC wins too because agreeing an ATCA saves time and effort testing whether each...
