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Official guidance
International Manual

INTM511000 · Thin capitalisation: practical guidance: introduction - contents

  • INTM511010 · Thin capitalisation: practical guidance: introduction: the aims of this module
  • INTM511015 · Thin capitalisation: practical guidance: introduction: what is thin capitalisation?
  • INTM511020 · Thin capitalisation: practical guidance: introduction: the aims of thin cap work
  • INTM511030 · Thin capitalisation: practical guidance: introduction: forms of borrowing
  • INTM511035 · Thin capitalisation: practical guidance: introduction: Critical features of debt and their interdependence
  • INTM511040 · Thin capitalisation: practical guidance: introduction: getting help with thin capitalisation cases
  • INTM511050 · Thin capitalisation: practical guidance: introduction: referrals to Business, Assets & International
  • 511035 · Thin capitalisation: practical guidance: introduction: Critical features of debt and their interdependence
  1. Thin capitalisation: practical guidance: introduction - contents
  2. Thin capitalisation: practical guidance: introduction: Critical features of debt and their interdependence

INTM511035 | Thin capitalisation: practical guidance: introduction: Critical features of debt and their interdependence

From HM Revenue & Customs · International Manual

Lending and borrowing decisions are influenced by the macroeconomic circumstances of the period leading up to signing of contracts; thus, lending decisions are more generous in buoyant economic conditions than those arising during more pessimistic conditions such as recession. Similarly, lending decisions are critically dependant on the credit risk of the borrower which in turn is influenced by factors such as leverage and interest cover. The currency denomination of debt is a further significant feature. In some circumstances, the introduction of a foreign exchange conversion from one currency to another can lead to unhedged exposure that can make such a deal unacceptable for both lenders and borrowers. Consideration should also be given to the combination of magnitude of debt and the maturity (or “tenor”) of the debt. Under any particular macroeconomic backdrop, for any specific credit risk and for any currency denomination, relatively larger amounts of debt will generally only be available for shorter maturities whilst smaller amounts will be available for longer maturities.

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