Corporation Tax: technical changes relating to Advance Pricing Agreements for certain financing arrangements
This tax information and impact note is about ensuring the validity of certain Advance Pricing Agreements relating to financing arrangements, in line with HMRC’s existing Statement of Practice 1 (2012).
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This measure amends both the transfer pricing and Advance Pricing Agreement legislation to ensure the validity of Advance Pricing Agreements in cases where the parties to the provision are only connected by virtue of acting together in relation to financing arrangements.