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HMRC internal manual

International Exchange of Information Manual

HM Revenue & Customs
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Action 5 rulings: Legislative basis for exchange

IEIM540200: Action 5: Legislative basis for exchange


Exchange of information in accordance with Action 5 is under the existing terms of the international agreements the UK has entered into (such as Double Taxation Conventions, Tax Information Exchange Agreements, and the Multilateral Convention on Mutual Administrative Assistance in Tax Matters). 

This means that the rulings and APAs will be exchanged where they are foreseeably relevant to another jurisdiction, and the factors in IEIM541010 apply.