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HMRC internal manual

International Exchange of Information Manual

Customers for whom rulings should be exchanged: Overview

IEIM524010: Customers for whom rulings should be exchanged: Overview


There are differences between the customers covered by the two agreements for automatic exchange.  The detailed guidance for:

  • Action 5 is at IEIM524100
  • The DAC is at IEIM524200

For the DAC the obligation to exchange only applies to rulings and APAs given to non-natural persons (so not individuals).  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.