Transfer pricing: methodologies: Advance Pricing Agreements: sample agreement

SP02/10- Advance Pricing Agreements Annex 2 – Sample Agreement

(instructions, explanations and comments in italics)

ADVANCE PRICING AGREEMENT

Between

TAXPAYER

And

H.M. REVENUE AND CUSTOMS

This Advance Pricing Agreement (‘APA’) is made between

Taxpayer, and

HM Revenue and Customs acting through CSTD Business, Assets & International (‘HMRC’)

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