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HMRC internal manual

International Exchange of Information Manual

Action 5 rulings: Definition of a ruing for Action 5

IEIM540100: Action 5 rulings: Definition of a ruling for Action 5


The Action 5 Final Report defines rulings as:

“any advice, information or undertaking provided by a tax authority to a specific taxpayer or group of taxpayers concerning their tax situation and on which they are entitled to rely.”

Such rulings may be given either before or after the event or transaction, but will be given before the return for the period is filed (IEIM520800).


Automatic exchanges in line with Action 5 are limited to rulings given in situations that could give rise to base erosion and profit shifting concerns.  The Final Report on Action 5 identifies five particular situations, which are described at IEIM541010. 

There is general guidance on the meaning of ruling at IEIM520000+.

The definition of APAs is at IEIM520200.