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HMRC internal manual

Oil Taxation Manual

Interest and Financing - Introduction

Financial Transfer Pricing is covered in depth in the International Manual at INTM500000 and sequence. This manual covers financing specific to the Oil & Gas sector (CTA10\S286 & S287, formerly at ICTA88\S494).

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 SP04\07.

North Sea Clearances have been superseded by the APA legislation.