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HMRC internal manual

International Exchange of Information Manual

HM Revenue & Customs
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What is a ruling: Transactions that are not carried out in accordance with the ruling

IEIM520600: What is a ruling? Transactions that are not carried out in accordance with the ruling


This advice relates to situations where you become aware that the original circumstances as notified have changed.

The customer may advise you that the transactions or events have not proceeded under the terms originally notified to HMRC, or this may become apparent when the return for the period is received.

If the variance from the original facts given are sufficient that the customer has no entitlement to rely on the ruling or APA, send details to JITSIC.  JITSIC will advise our treaty partners that the customer has not proceeded as previously advised.

If an amended ruling or APAs is given see the guidance at IEIM520400. 


Do not wait to see if the transaction takes place as notified

In terms of exchanging the initial ruling, it does not matter whether it is acted on after it has been given, and there is no requirement for you to confirm that the transaction has taken place; the ruling should be exchanged when the assurance is provided to the customer. 

See IEIM570400 for timings of exchange and when you need to send details to JITSIC.