[17 December 2010]

General introduction

This Statement of Practice (“SP”) updates an earlier Statement on Advance Pricing Agreements (“APAs”), published in 1999. The legislation that relates to APAs, formerly found at Section 85, Finance Act 1999, now appears at Sections 218–230 of the Taxation (International and Other Provisions) Act 2010 (“TIOPA 2010”). This SP is intended to provide guidance about how H.M. Revenue and Customs (“HMRC”) interprets the APA legislation and applies it in practice.

Key paragraphs in this SP

What is an APA? – para 1

What issues can be covered? – para 3

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