Advance Thin Capitalisation Agreement
(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 »