Question to the HM Treasury:

To ask Mr Chancellor of the Exchequer, pursuant to the Answer of 26 March 2018 to Question 133363 on Advance Pricing Agreements, for what reasons the UK counts Advance Pricing Agreements as a single case irrespective of the number of UK entities that may be party to the relevant agreement.

HM Revenue and Customs (HMRC) has run an Advanced Pricing Agreements (APA) programme since 1999 and records the number of applications and the number of agreements currently in force.

HMRC records each APA in force by reference to the application received, irrespective of the number of transactions included in the APA, or UK entities who are signatories to the APA. This reflects the way that HMRC processes an application, considering all aspects of a single application together.

The UK’s approach is in line with HMRC’s wider approach to publishing APA statistics and has been accepted by the European Joint Transfer Pricing Forum (EUJTPF).