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HMRC internal manual

International Exchange of Information Manual

Spontaneous exchange of rulings: Overview

IEIM530010: Spontaneous exchange of rulings: Overview


There are circumstances under which it would be foreseeably relevant to advise another jurisdiction of a ruling or advanced pricing agreement, even though there is no requirement to do so under Action 5 or the DAC. 

‘Ruling’ in the context of spontaneous exchange will still include all statutory and non-statutory clearances and more; you should refer to the guidance on legitimate expectation at IEIM520100. 

All advance cross-border rulings are required to be exchanged under DAC, but it may be that summary details of the ruling are foreseeably relevant to one or more non-EU states as well.  Details of the rulings should be exchanged on a spontaneous basis with any relevant non-EU jurisdictions, with which the UK has an exchange agreement.  JITSIC can handle with whom to exchange, so it is better to submit a ruling if you are in any doubt.

There may be circumstances where a ruling given to a natural person should be exchanged.

See the examples at IEIM530200.

It is unlikely that you will exchange Action 5 rulings more widely than with the relevant jurisdictions set out in IEIM540300. 


How to exchange rulings spontaneously

You should still provide the details to JITSIC using the template at IEIM570900.  Such rulings are still exchanged under an international agreement. Keeping track of the UK’s commitment to share rulings is extremely important, even outside of the remit of the particular agreements detailed in this guidance.  Further guidance on how and when to exchange is at IEIM570000+.