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HMRC internal manual

Oil Taxation Manual

Corporation tax ring fence: advance pricing agreements

Under TIOPA10\S218 (previously FA99\S85 to S87) HMRC may enter into Advance Pricing Agreements (APAs) in relation to transfer pricing, see INTM469010. The APA programme is co-ordinated by Business International but LBS Oil & Gas is responsible for operating the APA process in relation to issues specific to the energy industry. An application for a unilateral APA, or to informally explore the possibility of an APA, may be made direct to the Competent Authority at LBS Oil and Gas, Bush House, South West Wing, Strand, London, WC2B 4RD, or via the group’s Customer Relationship Manager if they have one.

Under HMRC governance arrangements, Bilateral applications should be sent to the competent authority at Business International, who will liaise with the competent authority at the LBS Oil & Gas Sector (APAs).

The APA process is set out in detail in Statement of Practice 2/10 and INTM469030 onwards.