INTM489875 | Diverted Profits Tax: customer engagement with HMRC: Diverted Profits Tax and Advance Thin Capitalisation Agreements

The 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.