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United KingdomGOV.UK

HMRC rewrites sample CCA advance pricing agreement

Sample CCA APA adds IP and Chapter VIII rules, narrows Annual Reports and bounds revocation with pre-revocation discussion.

By Taxxa AI OyPublished 3 November 2026

Tax

Industry: Across industries

HMRC has rewritten the operative clauses of its sample Cost Contribution Arrangement Advance Pricing Agreement. The new draft narrows what the agreement settles, ties it to a defined Covered Period with rollbackGOV, adds Intellectual Property and Chapter VIII Transfer Pricing Guidelines coverage, reshapes Annual Reports around rights and viability, and replaces broad revocation and cancellation language with bounded revocation plus pre-revocation processGOV.

Legal effect is now expressly for the Covered PeriodGOV: chargeable periods ending DDMMYYYY through DDMMYYYY, with a rollback to chargeable periods ended DDMMYYYY through DDMMYYYY. While the taxpayer is contractually a CCA participant, Part 4 of the Taxation (International and Other Provisions) Act 2010 applies as if participation were at arm's length; after contractual exit it applies as if past contractual participation had been at arm's length. Parties accept validity of participation and apply paragraph 8.15 of the 2022 OECD Guidelines accordingly, so anticipated benefits follow the CCA terms. Contributions must align with proportionate anticipated benefits under Chapter VIII, with buy-out and other rights likewise under Chapter VIII.

Coverage is itemised for profit calculations in the Covered Period: existing IP contributed at or before signing plus IP developed under the arrangement during the period; IP developed by group Z and contributed during the period; and IP acquired from third parties and contributed up to a stated period end. Development starts when non-negligible costs are incurred. The draft stresses what it does not do: it does not fix transfer prices or valuations, quantify other CCA payments, or certify the whole CCA as Chapter VIII compliant. Pricing and valuation of buy-in, balancing, exit and IP acquisition or disposal adjustments are expressly outside the material-change test.

Annual Reports remain due with the company corporation tax return, signed by the authorised person, and go to the Customer Compliance Manager or responsible office, with HMRC able to seek reasonably needed verification material. Content shifts to three statements: material changes to rights, beneficial entitlement or obligations since the original CCA; whether the taxpayer remains a contractual participant; and viability changesGOV. Pricing or valuation changes are not material changes. The former 90-day filing rule for already-filed returns, the general business-operations description, the critical-assumptions compliance statement and the power to cancel for late reports or information are gone.

Revocation is narrower and prospective. Non-compliance no longer ends effect by itselfGOV, and critical assumptions are removed. HMRC may revoke only where the CCA as amended ceases to be a CCA under Chapter VIII, or where later amendment or repeal of Part 4 or the Guidelines invalidates key premisesGOV, in each case only from the amendment chargeable period onwardsGOV. Before revoking it must explain in detail why the trigger is metGOV and allow reasonable opportunity to discuss and negotiate amendments in good faithGOV. Misrepresentation still leaves the agreement to be treated as never made under section 226. Those negotiating a CCA APA should reflect the new IP categories in the draft, confirm the Covered Period dates, and allow for the explanation-and-discussion step before any revocation. The legal basis is the Taxation (International and Other Provisions) Act 2010, sections 218 to 221 and 226, with Chapter VIII of the 2022 OECD Transfer Pricing Guidelines.

Reflect the new IP categories and Covered Period in CCA APA drafts and allow for pre-revocation discussion.

Sources