Taxation (International and Other Provisions) Act 2010 section 223

Application for agreement

Section 223 specifies the requirements that a taxpayer's application to HMRC for an advance pricing agreement must meet.

• An application for an advance pricing agreement must be made to HMRC and must seek to clarify, by agreement, how relevant tax provisions apply to the applicant's circumstances in relation to transfer pricing or related matters.
• The application must set out the applicant's own understanding of how the relevant tax provisions would apply to them if no agreement were reached.
• The application must identify the specific areas where the applicant considers that clarification of those provisions is needed.
• The application must propose how those matters should be clarified, in a way that is consistent with the applicant's stated understanding of the provisions.