HMRC internal manual

International Exchange of Information Manual

Customers for whom rulings should be exchanged.

You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.

Action 5 does not specify a particular type of customer, but the types of rulings within the report (IEIM541010) would tend to be given to corporates and larger partnerships.


Rulings provided to other customers

Although the types of customers for automatic exchange of rulings may be mainly legal persons, this does not mean that we should not exchange rulings given to natural persons. 

Such rulings should still be exchanged spontaneously where they are foreseeably relevant to another tax administration, in accordance with our obligations under the UK’s international tax agreements.  See IEIM530000+ for guidance on spontaneous exchange of tax rulings.