Thin Capitalisation
HMRC have published the model Statement of Practice on Advance Thin Capitalisation Agreements (ATCA's). It is expected that the model statement will streamline the process for companies wishing to obtain a forward agreement in respect of financing provisions to which schedule 28AA, ICTA 1988 applies.
The model Statement of Practice on Advance Thin Capitalisation is available at http://www.hmrc.gov.uk/cnr/draft-atca-v1.pdf.