For UK taxpayers, the method of reaching an advance pricing agreement is included in legislation at TIOPA 2010, ss 218–230 (Pt 5) and there is also a Statement of Practice, SP 2/10 on Advance Pricing Agreements and HMRC guidance at INTM422000 onwards. The details are summarised below.
Scope of an APA
A taxpayer may request an APA for matters relating to1:
- Ìý
•ÌýÌýÌýÌý the attribution of income to a branch or agency in the UK where the taxpayer is not a company
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•ÌýÌýÌýÌý the attribution of income to a permanent establishment in the UK where the taxpayer is a company
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•ÌýÌýÌýÌý the attribution of income to any permanent establishment through which the taxpayer carries on, or propose to carry on, a business
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•ÌýÌýÌýÌý the extent to which actual or prospective income of a UK taxpayer arises outside the UK
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•ÌýÌýÌýÌý the treatment of transactions between a taxpayer and an associate, and
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•ÌýÌýÌýÌý the treatment of transactions between an oil-related ring fenced trade carried on by
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