Advance Thin Capitalisation Agreement

TP Back to Basics – The HMRC ATCA Process

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This article is accompanied by a slide presentation on YouTube. Feel free to use my material for your own in-house purposes, all I ask is that you acknowledge the source. Read the rest of this entry »

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Advance Thin Capitalisation Agreements with HMRC

Posted on Updated on

(An article entitled “The HMRC ATCA Process” was published on this website on 12 February 2018, with an accompanying slide presentation on my YouTube channel.)

Transfer pricing should be a concern for all multinational enterprises (MNEs) operating in the UK.

The UK’s corporation tax self-assessment regime requires the taxpayer to ensure that their transfer pricing reflects ‘arm’s length’ prices on all related-party transactions, including UK-UK.

Interest and penalties may be imposed for non-compliance, even for businesses with losses, so there could be serious financial implications if a business does not take its transfer pricing obligations seriously. Read the rest of this entry »