OT20334 - Corporation Tax General

Advance Pricing Agreements.

Finance Act 1999 introduced new rules enabling taxpayers and the Revenue to enter into Advance Pricing Agreements (APAs) in relation to transfer pricing. Other parts of International are responsible for general oversight of the provisions, and their operation in non-oil cases, but OTO is responsible for operating the APA process in relation to oil taxation cases, and any points of difficulty should be referred in the first instance to the Assistant Director (OTO) holding the International portfolio. Following wide consultation, a Statement of Practice setting out the APA process in detail was issued in Autumn 1999.