HMRC internal manual

International Manual

INTM422080 - Transfer pricing: methodologies: Advance Pricing Agreements: evaluation


  1. On receipt of an application HMRC will evaluate its contents and will seek clarification and further information from the business as necessary. The examination of the application should be a co-operative process in which the transfer pricing issues are discussed openly and access to relevant supporting information and documentation is made available. Lack of co-operation in these respects may result in HMRC declining to give any further consideration to the application.
  2. Where a bilateral APA is being sought, HMRC will expect the business to continue to make relevant information available at the same time to each Administration involved, and in turn will itself keep the treaty partner informed about the progress of its examination of the APA request, will seek to discuss with the treaty partner key issues arising at the earliest opportunity and will keep the business informed about the progress of the bilateral process. Whilst the finalising of a bilateral agreement with a treaty partner is a government-to-government process, HMRC is generally prepared to participate in, and encourages, joint meetings involving the business and the other Administration(s) to assist in the exploration and evaluation of key factual issues.