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INTM480550 - Transfer Pricing: Operational guidance: real time working of transfer pricing issues: thin capitalisation You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.   HMRC recognises that consideration of issues in real time, including TP, allows HMRC to examine issues when information and relevant business personnel are more easily accessed and can provide a degree of reassurance for customers at an early stage that their return will be considered as presenting a low operational priority.  However, in working with business to assess TP risks in this way it is important to note the formal ATCA process is the only way a customer can be given certainty about the application of the thin capitalisation legislation. INTM413000, INTM510000 and Statement of Practice 01/12 provide a full explanation. INTM512000 provides practical guidance on all aspects of ATCAs.

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