Taxation (International and Other Provisions) Act 2010 section 221

Effect of revocation of agreement or breach of its conditions

Section 221 sets out the circumstances in which an advance pricing agreement ceases to have effect, including revocation by HMRC, breach of significant provisions, or failure to meet key conditions.

• An APA loses its effect if an HMRC officer has revoked it in accordance with its terms, for any period after the revocation takes effect.
• An APA loses its effect if a party to the agreement has failed to comply with a significant provision — that is, a provision whose compliance is stated in the agreement as a condition of the agreement having effect.
• An APA loses its effect in relation to any matter where a key condition of the agreement has not been met or is no longer met, where a key condition means any other condition stated in the agreement as necessary for it to have effect.
• In all three cases, the APA does not apply to questions or periods affected by the revocation, breach, or unmet condition.