Revenue and Customs. This Advance Pricing Agreement (“APA”) is made between Taxpayer, and The Taxpayer and HMRC (collectively “The Parties”) wish to enter into an APA, and to include in it an appropriate Transfer Pricing Methodology (“TPM”) to be applied to the transactions between the Taxpayer and the related party (or parties) identified below.
Appears in 3 contracts
Samples: Advance Pricing Agreement, Advance Pricing Agreement, Advance Pricing Agreement
Revenue and Customs. This Advance Pricing Agreement (“APA”) is made between Taxpayer, and The Taxpayer and HMRC (collectively “The Parties”) wish to enter into an APA, and to include in it an appropriate Transfer Pricing Methodology (“TPM”) to be applied to the transactions between the Taxpayer and the related party (or parties) identified below.. (This agreement replicates under UK statute on Advance Pricing Agreements the terms of a bilateral/multilateral agreement reached under the Mutual Agreement Procedure Article of the relevant Tax Treaty covering the same transactions between HMRC and (fisc(s))
Appears in 1 contract
Samples: Advance Pricing Agreement