KPMG have just published a case study on the new Advance Thin Capitalisation Agreements available from HM Revenue & Customs. The case study lays out the following scenario:
So "let's start with a wholly artificial structure and let's ask HM Revenue & Customs to agree all is OK" would appear to be KPMG's opening gambit.
Good, isn't it?
Incidentally, the stores subject to Tesco's sale and lease back are now partly owned by a JPUT. No coincidence though, I'm sure.