INTM489875 - Diverted Profits Tax: customer engagement with HMRC: Diverted Profits Tax and Advance Thin Capitalisation Agreements
»Ê¹ÚÌåÓýapp DPT exclusion for excepted loan relationship outcomes should mean that in most circumstances Advance Thin Capitalisation Agreements (ATCAs) will not be directly affected by DPT. Nevertheless, in cases where a group’s wider arrangements give rise to DPT risks it will be important to consider whether they also give rise to thin capitalisation issues.