Related Commentary  Related HMRC Manuals

218(1)  In this Part “advance pricing agreement” means a written agreement that–

(a)is made by the Commissioners with any person (“A”) as a consequence of an application by A under section 223,

(b)relates to one or more of the matters mentioned in subsection (2), and

(c)declares that it is an agreement made for the purposes of this section.

218(2)  Those matters are–

(a)if A is not a company, the attribution of income to a branch or agency through which A has been carrying on a trade in the United Kingdom or is proposing to carry on a trade in the United Kingdom,

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