IEIM520200 - What is a ruling: Definition of an advance pricing arrangement
IEIM520200: What is a ruling? Definition of an advance pricing arrangement
BEPS Action 5 requires the exchange of unilateral APAs and advance thin capitalisation agreements (ATCA). »Ê¹ÚÌåÓýapp full guidance on APAs and ATCAs is in the transfer pricing guidance (INTM410000).
As a starting point you should assume that all APAs and ATCAs agreed by HMRC, fall within the OECD.
»Ê¹ÚÌåÓýapp definition of APA is that used in the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as:
'’� an arrangement that determines, in advance of controlled transactions, as appropriate set of criteria � for the determination of the transfer pricing for those transactions over a fixed period of time.’�
»Ê¹ÚÌåÓýapp same applies to APAs concerning the attribution of profit to permanent establishments (IEIM541320).
»Ê¹ÚÌåÓýappre is more guidance about transfer pricing in the International Manual /government/collections/international-manual and advance pricing arrangements in the statement of practice /government/publications/statement-of-practice-2-2010/statement-of-practice-2-2010.