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HMRC internal manual

International Exchange of Information Manual

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Exchange of tax rulings: Exchange of past rulings

IEIM510550: Exchange of tax rulings: Exchange of past rulings

 

There is no need to automatically exchange any rulings or APAs made before 1 January 2010.

 

Dates for exchange of rulings and APAs under Action 5 (IEIM540010)

  • Rulings and APAs given on or after 1 January 2010 and still in effect at 1 January 2014

 

  • Rulings and APAs given on or after 1 January 2014, and before 1 April 2016 whether or not still in effect

 

These rulings and APAs must be exchanged by 31 December 2016.

 

Dates for exchange of rulings and APAs under the DAC (IEIM550010)

  • Rulings and APAs given on or after 1 January 2012 and still in effect at 1 January 2014

 

  • Rulings and APAs given on or after 1 January 2014 and before 31 December 2016, whether or not still in effect

 

These rulings and APAs must be exchanged by 31 December 2017.

 

Rulings and APAs made on or after 1 April 2016 but before 1 January 2017

Some rulings and APAs given on or after 1 April 2016 and before 1 January 2017 will need to be exchanged:

  • Within three months of its receipt by the UK competent authority (see IEIM510500) under Action 5

 

  • By 31 December 2017 under the DAC

 

The guidance at IEIM510500 gives the dates from which new rulings and APAs should be automatically being exchanged.