Commentary on Sections Overview
428.This Part provides the rules on APAs. These are written agreements between an enterprise and the Commissioners for HMRC which determine a method for resolving pricing issues in advance of a return being made. When the terms of the agreement are complied with they provide assurance that the treatment of those pricing issues will be accepted by both HMRC and the enterprise for the period covered by the agreement.
429.The APA legislation was put in place to enable HMRC to enter into APAs independently of pricing agreements under DTAs.
430.The Part sets out the matters which can be covered by an APA, what a taxpayer must do to obtain an agreement and how an agreement is applied.