Chapter INTM422070

Published date09 April 2016
Record NumberINTM422070
THE FORMAL APA APPLICATION {#}
  1. Where, following HMRC’s indication that it is willing to consider the APA proposal, the business wishes to proceed, it should submit a formal written application within 6 months or such longer period explicitly agreed at the expression of interest meeting. This APA application should also be copied to the business’ primary business contact at HMRC - usually the business’ Customer Compliance Manager. If there is a delay in submitting a written application HMRC reserves the right to not accept it.
  2. SP02/10- Advance Pricing Agreement Annex 1 to this document contains full details of the information that should be incorporated in the formal application. HMRC may, in practice, agree to be flexible with such requirements where the circumstances of the particular case mean that a different approach will make for a better process. In a bilateral case, HMRC is often able to agree to work from the same format application as is mandated by the other Administration’s procedures. These are issues best discussed with HMRC at the Expression of Interest stage. The application should ideally be made before the start of the first chargeable period proposed to be covered by the APA, but HMRC may exercise discretion over this, for instance, when a...

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