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HMRC internal manual

International Exchange of Information Manual

HM Revenue & Customs
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What is a ruling: General guidance versus specific advice

IEIM520700: What is a ruling? General guidance versus specific advice


General advice, such as advice that applies to all businesses, or particular groups of businesses, is excluded from the definition of a ruling.  Only advice or opinions that are tailored for a specific customer or group of customers, taking into account the factual situation of that customer, will count as rulings for the purposes of exchanging. 

So, for example, if you are asked a question by a customer or adviser about how a particular aspect of tax law works in general terms and you point them to published guidance, this would not be a ruling.  If, however, they provided facts particular to their circumstances and you tailored the advice for them, this would be a ruling within the rules outlined in this guidance.


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