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HMRC internal manual

International Exchange of Information Manual

Exchange of tax rulings: Overview

IEIM510010: Exchange of tax rulings: Overview of guidance, and taxes covered



‘Ruling’ is a term used in international taxation to refer to an agreement made between a tax authority and a customer, upon which the customer can rely.  Under certain circumstances rulings should be shared with other tax authorities to increase transparency and help to tackle international tax avoidance and evasion.

This guidance is for HMRC staff providing rulings, and for customers and advisers seeking rulings, and covers:

  • What is meant by the term ruling (IEIM520000+)
  • Automatic exchange of tax rulings, in particular:
  • Rulings under Action 5 of the OECD (Action 5) base erosion and profit shifting project (IEIM540000+)
  • Rulings under the amended EU Directive on Administrative Cooperation (DAC) (IEIM550000+)
  • Which customers are likely to be covered by automatic exchange of rulings (IEIM524000)
  • Circumstances when a spontaneous exchange of a particular ruling should be made (IEIM530000+)
  • What and how exchanges of tax rulings should be made (IEIM570000+)


An introduction to the subject of exchange of rulings is at IEIM510020.


Taxes to which this guidance applies

This guidance applies to all direct taxes, including corporation tax, income tax, capital gains tax, and withholding taxes.  It does not apply to VAT, custom duties, excise duties or compulsory social security contributions.