HMRC’s revised guidance on ATCA applications ie on agreements between HMRC and the taxpayer as to what constitutes an acceptable arm’s-length position concerning related party debt is contained in Statement of Practice SP 1/12 published on 3 February 2012 replacing SP 4/07. Readers may recall that around the time that SP 4/07 was published in the summer of 2007 the phrase ‘credit crunch’ was first being heard. Before then banks seemed to be lending to virtually anyone government debt was typically considered to be risk free and ratings agencies only featured in the finance pages of the media. Few would have guessed then that five years later and the position would have turned full circle.
