Tulip Siddiq – 2016 Parliamentary Question to the HM Treasury
The below Parliamentary question was asked by Tulip Siddiq on 2016-05-06.
To ask Mr Chancellor of the Exchequer, how many advance pricing arrangements (APAs) were agreed between companies and his Department in each year since 2009-10; how many such arrangements resulted in a (a) positive and (b) negative yield to the Exchequer; what the net amount raised by these APAs was in each such year; and how many APAs were annulled by HM Revenue and Customs in each such year.
Mr David Gauke
HM Revenue and Customs (HMRC) publishes annual statistics reporting its performance across its transfer pricing work, including enquiries, advance pricing agreements, advance thin capitalisation agreements and mutual agreement procedure cases. The most recent published statistics are for 2013- 14. HMRC intends to publish the statistics for 2014-15 shortly. These statistics answer many of the individual questions asked. However, HMRC does not hold information centrally in a form which allows it to answer all the questions asked in the required timeframe.
The aim of the Advance Pricing Arrangements (APA) Programme is to provide businesses with certainty on the pricing of complex intra-group transactions. An APA sets out the method for determining, in accordance with the law, the transfer price for intra-group transactions. APAs are part of the internationally recognised best practices recommended by the OECD. HMRC has published guidance about what APAs are, the circumstances where it would be appropriate for businesses to apply for an APA and what information is required before any agreement can be made.
