Taxation (International and Other Provisions) Act 2010 section 225

Modification and revocation of agreement

Section 225 deals with the timing of any modification or revocation of an advance pricing agreement (APA) where HMRC has the power to modify or revoke it.

• An APA may include provisions giving HMRC (the Commissioners or an officer) the power to modify or revoke the agreement.
• Where such powers exist, the APA may also allow HMRC to determine the time from which any modification or revocation takes effect.
• The effective date chosen by HMRC can be set retrospectively — that is, it can be a date before the modification is actually made or the agreement is actually revoked.
• There is no requirement for the effective date to be retrospective; HMRC may equally choose a current or future date.