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HMRC internal manual

International Exchange of Information Manual

HM Revenue & Customs
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Customers for whom information should be exchanged: The DAC: Partnerships

IEIM524500: Customers for whom rulings should be exchanged: the DAC: Partnerships


The requirement to exchange rulings does not apply where an advance cross-border ruling exclusively concerns and involves the tax affairs of one or more natural persons, see IEIM524200.

Partnerships are not natural persons and therefore fall within the scope of the DAC. However as it is the partners who are liable to pay tax on the profits and gains of the partnership, it is only rulings given to non-natural partners that should be exchanged.  Details of natural persons should be redacted.  JITSIC can provide advice on how this should be undertaken.


Ruling given to a partnership with partners that are all natural persons

The ruling is not exchangeable under the DAC.


Ruling given to a partnership with a mixture of partners who are natural person and non-natural entities

The ruling is exchangeable under DAC, but only in respect of the non-natural partners.  Care should be taken to ensure that the ruling does in fact apply to the non-natural partners and that information relating to natural partners is not exchanged (including how many there are).

For example, the ruling may apply to the computation and allocation of the partnership profits. This will only be exchangeable in relation to the computation and allocation of profit to the non-natural partners. If the ruling does not affect the tax affairs of a non-natural partner the information should not be exchanged.