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HMRC internal manual

International Exchange of Information Manual

HM Revenue & Customs
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Exchange of tax rulings: Introduction

IEIM510020: Exchange of tax rulings: Introduction



‘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.  In HMRC, this includes statutory and non-statutory clearances, and other types of assurance about a customer’s tax position.  This guidance gives detailed explanations of what is included in the term ruling (IEIM510100), and what you need to do when making a ruling in terms of sharing that ruling with other tax authorities.

The requirement to exchange customer-specific rulings includes the requirement to exchange APAs, including advance thin capitalisation agreements.


Why we exchange rulings

Rulings facilitate the consistent and transparent application of the law, providing certainty for business.  They encourage investment and compliance with the law, and it is good customer service for tax authorities to provide such services.  

The nature of multi-national business means that rulings provided by one tax authority have the potential to have an impact on the tax treatment of that or a related business in another jurisdiction.  Knowing about rulings given by other tax authorities provides information on our customers’ activities overseas, and improves our understanding of their businesses.   It also assists our ability to identify and tackle tax risks, such as cross-border tax avoidance, aggressive tax planning, and harmful tax practices. 


Recent progress in exchange of rulings

Changes to EU law and international best practice during 2015 reinforce the requirement for HMRC to exchange our cross border tax rulings and APAs with other jurisdictions using the legal gateways of international tax agreements (see IEIMXXX).  For the same reasons, we expect to see a significant increase in the number of rulings being sent to us by other tax authorities. 

Automatic exchange of certain new rulings began in April 2016, and with increased exchange from 1 January 2017 (IEIM510500).  HMRC will also exchange past rulings and APAs, in some cases back to those made in January 2010 (IEIM510550).

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)