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HMRC internal manual

International Exchange of Information Manual

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The DAC: Meaning of cross-border transaction for APAs

IEIM550600: The DAC: Meaning of cross-border transaction for APAs

For the purposes of the DAC a ‘cross-border transaction’ means a transaction (or series of transactions):

  • Involving associated enterprises which are not all resident for tax purposes in the territory of a single jurisdiction
  • Which have a cross border impact

 

There is no definition of the term ‘cross border impact’, but the term should take its natural meaning.

The term ‘enterprise’ is defined at article 3 paragraph 17 as ‘any form of conducting business’.