INTM574070 - Thin capitalisation: treaty clearances

Treaty clearance and a working thin capitalisation case: assessments under ICTA88/SCH16

If it is contemplated that an assessment is to be made to recover lost tax involving intra-group interest payments from the UK, then it should be noted that HM Revenue & Customs has developed a practice in connection with this. Details can be found from INTM574020 onwards.