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To ask His Majesty's Government how many advance transfer pricing agreements have been signed by HM Revenue and Customs in each of the past five years.
To ask His Majesty's Government how many advance transfer pricing agreements have been signed by HM Revenue and Customs in each of the past five years.
HM Revenue and Customs has entered into the following number of advance pricing agreements in the past five tax years:
- 2018 to 2019: 30
- 2019 to 2020: 26
- 2020 to 2021: 24
- 2021 to 2022: 20
- 2022 to 2023: 15
This information is included in the Transfer Pricing and Diverted Profits Tax Statistics 2022 to 2023 which are publicly available and published on gov.uk[1].
[1] Transfer Pricing and Diverted Profits Tax statistics 2022 to 2023 - GOV.UK (www.gov.uk)
To ask the Chancellor of the Exchequer, how many applications for Advance Thin Capitalisation Agreements were made in 2017-2018.
To ask the Chancellor of the Exchequer, how many applications for Advance Thin Capitalisation Agreements were made in 2017-2018.
HMRC publishes data regarding Advanced Thin Capitalisation Agreements (ATCAs) on an annual basis. The latest publication which covers data up to 2017-18 is available at the following link:
Information for 2018-19 will be published later this year. This will include the number of Advanced Thin Capitalisation Agreements HMRC has entered into during the year. HMRC does not currently centrally record and monitor the number of applications made in the year.
To ask the Chancellor of the Exchequer, how many Advanced Thin Capitalisation Agreements his Department entered into in 2018-2019.
To ask the Chancellor of the Exchequer, how many Advanced Thin Capitalisation Agreements his Department entered into in 2018-2019.
HMRC publishes data regarding Advanced Thin Capitalisation Agreements (ATCAs) on an annual basis. The latest publication which covers data up to 2017-18 is available at the following link:
Information for 2018-19 will be published later this year. This will include the number of Advanced Thin Capitalisation Agreements HMRC has entered into during the year. HMRC does not currently centrally record and monitor the number of applications made in the year.
To ask the Chancellor of the Exchequer, how much revenue has accrued to the public purse from anti-avoidance measures to tackle groups of companies using intra-group loans or derivatives to reduce the group’s tax bill.
To ask the Chancellor of the Exchequer, how much revenue has accrued to the public purse from anti-avoidance measures to tackle groups of companies using intra-group loans or derivatives to reduce the group’s tax bill.
There have been a large number of measures over the years which operate to counter Corporation Tax avoidance using intra-group loans and derivatives. The key measures are the ‘unallowable purpose’ rules (sections 441 and 690 of Corporation Tax Act 2009), the transfer pricing rules (Part 4 of Taxation (International and Other Provisions) Act 2010 (“TIOPA 2010”)), the group mismatch scheme rules (Part 21B of Corporation Tax Act 2010 (“CTA 2010”)), the tax mismatch scheme rules (Part 21BA of CTA 2010), the hybrid and other mismatches rules (Part 6A of TIOPA 2010), the controlled foreign companies rules (Part 9A of TIOPA 2010) and the corporate interest restriction rules (Part 10 of TIOPA 2010). Taken together these measures have been successful in protecting revenues, but it is not possible to say how much would otherwise have been lost.
To ask Mr Chancellor of the Exchequer, how many Advanced Thin Capitalisation Agreements have been agreed to in each month in each of the last two years.
To ask Mr Chancellor of the Exchequer, how many Advanced Thin Capitalisation Agreements have been agreed to in each month in each of the last two years.
HMRC publishes data regarding Advanced Thin Capitalisation Agreements (ATCAs) on an annual basis. The latest publication covers 2011/12 to 2016/17 and is available at the following link.
Information for 2017/18 will be published in due course.
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.
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).
To ask Mr Chancellor of the Exchequer, for what reasons the Government has not complied with the requirements of the European Union Joint Transfer Pricing Forum in providing statistics on the number of Advance Pricing Agreements in force for the fifth consecutive year.
To ask Mr Chancellor of the Exchequer, for what reasons the Government has not complied with the requirements of the European Union Joint Transfer Pricing Forum in providing statistics on the number of Advance Pricing Agreements in force for the fifth consecutive year.
The UK has complied with the requirements of the European Union Joint Transfer Pricing Forum and provided statistics on the number of Advance Pricing Agreements in force.
The statistics are available at: https://ec.europa.eu/taxation_customs/business/company-tax/transfer-pricing-eu-context/joint-transfer-pricing-forum_en
To ask Mr Chancellor of the Exchequer, pursuant to the Answer of 24 April 2017 to Question 70304, how many Advance Thin Capitalisation agreements were made in (a) 2014-15, (b) 2015-16 and (c) 2016-17; how long it took to reach each such agreement; how many such agreements are still in...
To ask Mr Chancellor of the Exchequer, pursuant to the Answer of 24 April 2017 to Question 70304, how many Advance Thin Capitalisation agreements were made in (a) 2014-15, (b) 2015-16 and (c) 2016-17; how long it took to reach each such agreement; how many such agreements are still in...
HM Revenue and Customs (HMRC) has published Advance Thin Capitalisation Agreement (ATCA) statistics to 2016/17, as part of a wider publication of data relating to HMRC’s work on collecting tax owed to the UK. This is available at the following link:
To ask Mr Chancellor of the Exchequer, how many Advance Thin Capitalisation agreements were made in (a) 2014-15 and (b) 2015-16; how long it took to reach each such agreement; how many such agreements are still in force; how many intra-group company bodies apply to those agreements; and what the...
To ask Mr Chancellor of the Exchequer, how many Advance Thin Capitalisation agreements were made in (a) 2014-15 and (b) 2015-16; how long it took to reach each such agreement; how many such agreements are still in force; how many intra-group company bodies apply to those agreements; and what the...
HM Revenue and Customs (HMRC) intends to publish Advanced Thin Capitalisation Agreement statistics in due course as part of a wider publication of data relating to HMRC’s work on collecting tax owed to the UK.
To ask Her Majesty’s Government what was (1) the weighted average interest rate for intra-group loans under Advance Thin Capitalisation Agreements (ATCAs), and (2) the average level of taxable profits to which ATCA-related tax relief applied, in each year since 2010.
To ask Her Majesty’s Government what was (1) the weighted average interest rate for intra-group loans under Advance Thin Capitalisation Agreements (ATCAs), and (2) the average level of taxable profits to which ATCA-related tax relief applied, in each year since 2010.
HM Revenue and Customs does not hold this information in a form which allows it to be provided without incurring disproportionate cost.
To ask Her Majesty’s Government what was the total volume of intra-group loans (1) for which Advance Thin Capitalisation Agreements (ATCAs) applied, and (2) in relation to which new ATCAs came into force, in each year since 2010.
To ask Her Majesty’s Government what was the total volume of intra-group loans (1) for which Advance Thin Capitalisation Agreements (ATCAs) applied, and (2) in relation to which new ATCAs came into force, in each year since 2010.
HM Revenue and Customs does not hold this information in a form which allows it to be provided without incurring disproportionate cost.
To ask Her Majesty’s Government how many Advance Thin Capitalisation Agreements (1) were agreed, and (2) were in force, in (a) 2014–15, and (b) 2015–16.
To ask Her Majesty’s Government how many Advance Thin Capitalisation Agreements (1) were agreed, and (2) were in force, in (a) 2014–15, and (b) 2015–16.
HM Revenue and Customs (HMRC) intends to publish Advanced Thin Capitalisation Agreement statistics in due course as part of a wider publication of data relating to HMRC’s work on collecting tax owed to the UK.
To ask Her Majesty’s Government how long it took to agree 50 per cent of Advance Thin Capitalisation Agreements in (1) 2014–15, and (2) 2015–16.
To ask Her Majesty’s Government how long it took to agree 50 per cent of Advance Thin Capitalisation Agreements in (1) 2014–15, and (2) 2015–16.
HM Revenue and Customs (HMRC) intends to publish Advanced Thin Capitalisation Agreement statistics in due course as part of a wider publication of data relating to HMRC’s work on collecting tax owed to the UK.
To ask Her Majesty’s Government what was the average time to reach an Advance Thin Capitalisation Agreement in (1) 2014–15, and (2) 2015–16.
To ask Her Majesty’s Government what was the average time to reach an Advance Thin Capitalisation Agreement in (1) 2014–15, and (2) 2015–16.
HM Revenue and Customs (HMRC) intends to publish Advanced Thin Capitalisation Agreement statistics in due course as part of a wider publication of data relating to HMRC’s work on collecting tax owed to the UK.
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...
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...
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.
To ask the Chancellor of the Exchequer how many advanced pricing agreements (a) have been made and (b) were in force with multinational companies in each year since 2001; and in how many cases in each year (i) enforcement action was taken and (ii) penalties were imposed in transfer pricing...
To ask the Chancellor of the Exchequer how many advanced pricing agreements (a) have been made and (b) were in force with multinational companies in each year since 2001; and in how many cases in each year (i) enforcement action was taken and (ii) penalties were imposed in transfer pricing...
To ask the Chancellor of the Exchequer how many advance pricing agreements (a) have been made and (b) were in force with multinational companies in each year since 2001; and in how many cases in each year (i) enforcement action was taken and (ii) penalties made in transfer pricing disputes.
To ask the Chancellor of the Exchequer how many advance pricing agreements (a) have been made and (b) were in force with multinational companies in each year since 2001; and in how many cases in each year (i) enforcement action was taken and (ii) penalties made in transfer pricing disputes.
| Number | In force at end of each year | |
| 2000-01 | 6 | 5 |
| 2001-02 | 9 | 14 |
| 2002-03 | 6 | 16 |
| 2003-04 | 10 | 22 |
| 2004-05 | 10 | 22 |
| 2005-06 | 7 | 18 |
| Number | |
| 2001-02 | 1,022 |
| 2002-03 | 1,172 |
| 2003-04 | 1,671 |
| 2004-05 | 1,588 |
| 2005-06 | 1,724 |
To ask Mr Chancellor of the Exchequer, how many advanced pricing agreements (a) have been made and (b) were in force with multinational companies in each year since 1996; and in how many cases each year enforcement action or penalties were taken in transfer pricing disputes. - Inc table.
To ask Mr Chancellor of the Exchequer, how many advanced pricing agreements (a) have been made and (b) were in force with multinational companies in each year since 1996; and in how many cases each year enforcement action or penalties were taken in transfer pricing disputes. - Inc table.
Finance Bill. Committee stage thirteenth sitting (afternoon). Schedules 10 and 11 agreed to. Clauses 71 to 91 agreed to.
Finance Bill. Committee stage thirteenth sitting (afternoon). Schedules 10 and 11 agreed to. Clauses 71 to 91 agreed to.
To ask Mr Chancellor of the Exchequer, if he will publish the results of the advance pricing agreement consultation process. - Including ref to Press Release dated 17 December 1998.
To ask Mr Chancellor of the Exchequer, if he will publish the results of the advance pricing agreement consultation process. - Including ref to Press Release dated 17 December 1998.