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HMRC internal manual

International Exchange of Information Manual

What is a ruling: Advice before or after the event

IEIM520800: What is a ruling? Advice before or after the event

Both pre- and post-transaction rulings must be exchanged. 


Pre-transaction rulings

A pre-transaction ruling is one which is given before the transaction takes place.  This will be the most common, as normally our customers will come to us for our opinion or agreement before they undertake a transaction or series of transactions.


Post-transaction rulings

A post-transaction ruling is one that is given after the transaction has been undertaken but before the tax return for that period is filed. 

Post-transaction rulings will normally arise where the event has happened, but because of new external advice, a change in the law or HMRC’s view, or other circumstances, the customer is uncertain how the transaction should be treated in the tax return.  This may also arise in the course of real time working (IEIM520900).


After the return is final

Where HMRC provides advice or an opinion both after the event and once the return is filed, this will not normally amount to a ruling unless the intention is to consider how the treatment should be for future taxable periods.  For HMRC to look at an event after the return is filed will be rare outside the context of an enquiry (IEIM520900).