UK: Updated manual on advance pricing agreements (APAs) and cost contribution arrangements (CCAs)

Includes guidance confirming APAs will be available for CCAs

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June 26, 2025

HM Revenue & Customs (HMRC) updated its international manual on advance pricing agreements (APAs) and cost contribution arrangements (CCAs) with guidance and a sample agreement, confirming that groups with existing development CCAs (whether under inquiry or not) can request an APA.

In addition, the guidance confirms that HMRC is open to agreeing to an APA term of longer than five years, taking into account the expected duration of the development projects subject to the CCA.

The updated guidance follows the consultation announced this spring regarding the intent to offer clearance on the treatment of CCAs through the existing legislation on APAs. Read TaxNewsFlash

Read a June 2025 report prepared by the KPMG member firm in the UK

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