UK HMRC publishes guidance on Unilateral Advanced Pricing Agreement process for Cost Contribution Arrangements
|Tax Alerts, National/Federal Taxation, T ...|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…
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