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HMRC internal manual

International Exchange of Information Manual

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Exchange of tax rulings: With which jurisdictions to exchange

IEIM510400: Exchange of tax rulings: With which jurisdictions to exchange

 

Both the Action 5 and the DAC set out with whom rulings should be exchanged; there are different requirements for each. 

The OECD requirement means that rulings and APAs will only be shared with those jurisdictions that have committed to implement the base erosion and profit shifting framework set out in Chapter 5 of Action 5. 

The DAC requires a summary of the ruling to be posted onto the EU database accessible to tax authorities.  Member States may follow up to request further details where the information is foreseeably relevant.  There is further guidance via the links at IEIM550300.

HMRC is committed to honouring the spirit, as well as the letter, of the UK’s international treaty obligations with respect to exchange of information, and will spontaneously exchange rulings that fall outside the scope of Action 5 and the DAC where the information is foreseeably relevant to the treaty partner (IEIM530000+).