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HMRC internal manual

International Exchange of Information Manual

HM Revenue & Customs
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Exchange of tax rulings: Different obligations

IEIM510200: Exchange of tax rulings: Different obligations

The UK, along with other jurisdictions, already spontaneously exchanges tax rulings with the other jurisdictions. 

Our international tax agreements, such as Double Taxation Conventions and the EU Directive on Administrative Cooperation (INTM156010), both allow and oblige HMRC to spontaneously exchange rulings where they are foreseeably relevant to the other jurisdiction – but more than that, we exchange them because we want to be good treaty partners, and increase tax transparency.

Building on and enhancing the existing practice, in 2015 two separate agreements were made at an international level that created an obligation to automatically exchange certain rulings. 

Under these agreements we will have access to a wealth of information on our customers’ activities overseas, improving our ability to identify and tackle tax risks.



By consensus through various international working parties, the Organisation for Economic Cooperation and Development (OECD) is one of the bodies that sets the standard for exchange of information. 

In 2015, as part of the Final Report on Action 5 of their Base Erosion and Profit Shifting (BEPS) project, the OECD published a guide on the best practice for exchange of tax rulings and APAs.  As a member of the OECD, and a key driver in the base erosion and profit shifting project, the UK has implemented the recommendations of the report with effect from 1 April 2016 (IEIM510500). 

The guidance on the exchange of Action 5 rulings is at IEIM540000+.


The European Union

The UK exchanges tax information with other EU Member States under the EU Directive on Administrative Cooperation in the field of taxation (Directive 2011/16/EU), known as the DAC. As well as being an instrument allowing exchange, the DAC also lists various mandatory situations where Member States must share information.

In an update to the DAC, it became mandatory to automatically exchange information about advance cross-border rulings and APAs as from 1 January 2017.  The amending Directive which adds this requirement can be found on the Official Journal of the European Union.

The guidance on the exchange of rulings under the DAC is at IEIM550000+.