(1)In this Part “advance pricing agreement” means a written agreement that—
(a)is made by the Commissioners with any person (“A”) as a consequence of an application by A under section 223,
(b)relates to one or more of the matters mentioned in subsection (2), and
(c)declares that it is an agreement made for the purposes of this section.
(2)Those matters are—
(a)if A is not a company, the attribution of income to a branch or agency through which A has been carrying on a trade in the United Kingdom or is proposing to carry on a trade in the United Kingdom,
(b)if A is a company, the attribution of income to a permanent establishment through which A has been carrying on a trade in the United Kingdom or is proposing to carry on a trade in the United Kingdom,
(c)the attribution of income to any permanent establishment of A’s, wherever situated, through which A has been carrying on, or is proposing to carry on, any business,
(d)the extent to which income that has arisen or may arise to A is to be taken for any purpose to be income arising in a country or territory outside the United Kingdom,
(e)the treatment for tax purposes of any provision made or imposed, whether before or after the date of the agreement, as between A and any associate (see section 219) of A’s, and
(f)the treatment for tax purposes of any provision made or imposed, whether before or after the date of the agreement, as between an oil-related ring-fence trade carried on by A (see section 206) and any other activities carried on by A.