HMRC publishes final guidance on advance thin capitalisation pricing agreements | Practical Law
On 28 November 2007, HM Revenue & Customs (HMRC) published Statement of Practice 04/07, which extends the circumstances in which a UK business can enter into a thin capitalisation advance pricing agreement with HMRC under the transfer pricing legislation. The agreement will provide the taxpayer with certainty as to the tax deductibility of interest payments made in accordance with the agreement.