INTM582000 - Thin capitalisation: agreements between HM Revenue & Customs and the group
Contents
Introduction to the main features of the agreement |
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Maximum amount of loan or facility |
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Interest rate |
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Length of the agreement |
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Covenant conditions |
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Consequences of a covenant breach |
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Covenant breaches and unforeseen circumstances |
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Monitoring conditions |
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Example of an agreement - the Model ATCA |
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Example of an agreement: Model ATCA - appendix 1 - interest cover ratio |
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Example of an agreement: Model ATCA - appendix 2 - gearing ratio |
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Example of an agreement: Model ATCA - appendix 3 - short accounting period |
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Example of an agreement: Model ATCA - commentary on the agreement |
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Making a recommendation to Charity Assets & Residence on pre-ATCA cases |

