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HMRC internal manual

International Manual

HM Revenue & Customs
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Transfer pricing: methodologies: Advance Pricing Agreements: typical timeline

SP2/10 Annex 2

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This flowchart shows a timeline for a typical advance pricing agreement. It shows a possible timescale for the case team, the competent authority and other tax administrations covering a 21 month period.

For all three there will be a lead in period during which the case team and other administrations will have no substantial involvement, although competent authority will be involved in some activity.

When the APA process starts the case team will be involved in intense activity over the first 9 months researching and testing the proposal, with less intense activity over the same period by competent authority. The other administration will not be substantially involved during this period.

The detail of the APA will occupy 3 months following the research and testing period, when again the case team will be heavily involved.

Between 12 and 18 months all three parties will be heavily involved most of the time in resolving the APA.

Finally from 18 to 21 months there will be a final period of intense activity for closing paperwork, during which the case team will be less heavily involved.