SP02/10 – Advance Pricing Agreements Annex 1 – Information to set out in the Formal Application

(1)The application should fulfil the requirements of Section 223, TIOPA 2010 and set out:

the applicant's understanding of the effect of the relevant legislation including the effect of any DTA in relation to the transfer pricing issues under consideration;

the areas where clarification of that effect is sought; and

a proposal for clarifying the effect of the legislation in accordance with the applicant's understanding.

(2)All proposals will also need to be supported by the following information:

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