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Advance Pricing Agreements

Volume 448: debated on Thursday 6 July 2006

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. (82680)

The information requested is as follows.

(a) and (b) The number of advance pricing agreements within s85 FA99 made in each year (and in force at the end of each year) was:

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

All agreements relate to multinational companies.

(i) The number of occasions where an Inland Revenue/HMRC intervention has resulted in a transfer pricing adjustment to a tax computation are:

Number

2001-02

1,022

2002-03

1,172

2003-04

1,671

2004-05

1,588

2005-06

1,724

(ii) Penalties following transfer pricing inquiries have been agreed on five cases. These all fall in 2005-06.