OT22001 - Interest and Financing - Introduction

Financial Transfer Pricing is covered in depth in the International Manual at INTM500000 onwards. This manual covers financing specific to the Oil & Gas sector (CTA10\S286 & S287).

Under the legislation for Advance Pricing Agreements (APA, see TIOPA10\S218 formerly FA99\S85) it is possible to request an Advance Thin Capitalisation Agreement (ATCA). Details of this process can be found in SP01\12 (see INTM520085).