Taxation (International and Other Provisions) Act 2010 section 231

Overview

Section 231 provides an overview of Part 5 of the Act, which deals with the advance pricing agreement regime allowing businesses and HMRC to agree in advance the pricing of cross-border transactions between connected parties.

• Part 5 establishes the framework for advance pricing agreements (APAs) between businesses and HMRC regarding transfer pricing of cross-border transactions.
• APAs allow businesses to agree in advance how the arm's length principle will apply to specific transactions, providing certainty and reducing the risk of future disputes.
• The regime covers the process for applying for, entering into, and administering APAs, including their duration and any amendments or revocations.
• The provisions were amended by Finance Act 2016 to update and refine the APA regime.