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EY Global Tax Controversy Flash Newsletter (Issue 81) | Unilateral APAs may now be used to solve Cost Sharing Arrangements disputes
In March 2025, His Majesty’s Treasury announced that taxpayers may now apply for unilateral Advance Pricing Agreements (APAs) to gain certainty on the recognition of Cost Contribution Arrangements (CCAs) through the UK's APA program. Applications are now possible, including for taxpayers currently under enquiry. Details are available in our EY Tax Alert.
This March development is a response to His Majesty's Revenue & Customs (HMRC) January 2024 operational guidance on their interpretation of the role of risk control in a transfer pricing analysis (see this EY Tax Alert for details). In their application of this framework, HMRC raised concerns with taxpayers over their participation in CCAs, and the requisite control over risk to be evidenced.
Additional information and links to past newsletters can be found in the attached PDF.