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HMRC internal manual

Oil Taxation Manual

Non-residents working on the UK continental shelf: transfer pricing: advance pricing agreements

Historically it has been HMRC’s policy to encourage applications for Advance Pricing Agreements (APAs) in this area and these were made to LB London. However practice has changed.

All requests for an APA must now be made to CTIS and customers interested in an APA should contact Nick Stevart to informally discuss whether it would be suitable for the HMRC APA programme. The APA Statement of Practice SP02/10 has further details and is expected to be updated to clarify evolving best practice. Unilateral applications that may have been accepted into the APA program by LB London in the past may no longer be seen as an appropriate use of HMRC’s resources

Following the introduction of the hire cap legislation in April 2014 the necessity for establishing the correct transfer price has become less of a risk for HMRC for those cases covered by Part 8ZA CTA 2010.  See OT50000 onwards.