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HMRC internal manual

International Exchange of Information Manual

HM Revenue & Customs
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Action 5 rulings: Types of rulings to exchange: Other rulings related to transfer pricing

The requirement to exchange unilateral rulings relating to transfer pricing also extends to transfer pricing issues that fall short of a unilateral Advanced Pricing Agreement (APA) or Advance Thin Capitalisation Agreement (ATCA), such as:

  • A ruling that is limited to addressing questions of a legal nature based on the facts presented
  • A ruling that is binding only for a particular transaction (unlike an APA which usually covers several transactions, or all transactions for a given period of time)
  • An agreement on future transfer pricing methodology, future pricing of profit apportionment structure


As for actual APAs and ATCAs, such rulings will only need to be exchanged automatically under Action 5 where they are made unilaterally (IEIM541200).

Whether unilateral or bilateral, these rulings will need to be exchanged automatically under the DAC (IEIM550010), but special rules will apply where these are bilateral (IEIM550500).