http://www.legislation.gov.uk/ukpga/2010/8/section/222Taxation (International and Other Provisions) Act 2010An Act to restate, with minor changes, certain enactments relating to tax; to make provision for purposes connected with the restatement of enactments by other tax law rewrite Acts; and for connected purposes.texttext/xmlenStatute Law Database2026-05-05Expert Participation2026-03-18 Part 52221Subsections (2), (5) and (6) apply if—aan advance pricing agreement has effect in relation to any provision (“the actual provision”) made or imposed as between any person (“A”) and another (“B”), andbsection 220(2) has the effect in A's case of requiring a question relating to the actual provision to be determined in accordance with the agreement rather than by reference to rules which would otherwise be applicable because of Part 4.2The provisions mentioned in subsection (3) have effect in B's case on the assumption that any question within subsection (4) is to be determined, to the same extent as in A's case, by reference to the agreement.3The provisions are—sections 174 to 178 (transfer pricing: claim by disadvantaged person), andsections 188 and 189 (transfer pricing: adjustment of double taxation relief if claim made).4The questions are—awhether A is a person on whom a potential advantage in relation to United Kingdom taxation is conferred by the actual provision, andbwhat constitutes the arm's length provision in relation to the actual provision.5Subsection (2) has effect subject to any advance pricing agreement made between the Commissioners and B.6Any assumptions to be made because of the agreement are “advance-pricing-agreement assumptions” for the purposes of paragraph (b) of the definition in section 185(5) of “transfer-pricing determination”.