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 »


Advance Thin Capitalisation Agreements with HMRC

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(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 »