UK HMRC publishes guidance on Unilateral Advanced Pricing Agreement process for Cost Contribution Arrangements

27 June 2025|Tax Alerts, National/Federal Taxation, Transfer Pricing, Global|United Kingdom

On 19 June 2025, Majesty's Revenue & Customs (HMRC) published guidance and a sample draft agreement for unilateral Advance Pricing Agreements (APAs) covering Cost Contribution Arrangements (CCAs), providing a pathway for United Kingdom (UK) entities to gain certainty on their participation in CCAs.
The new provisions allow businesses to apply for APAs to confirm the validity of their CCA participation, with the potential for rollback to past periods, which is a significant shift from previous…

Continue reading with a Pro Subscription

Unlock full Orbitax Tax News content, including a historical database of tax news, alerts, and analysis from our network of tax experts, all tailored to your company footprint. Now includes Orbitax XatBot AI Tax Assistant.

Free trial available. Cancel anytime. Free Orbitax account required.