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HMRC internal manual

International Exchange of Information Manual

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Action 5 rulings: Types of rulings to exchange: Attribution of profits to a permanent establishment

IEIM541320: Action 5 rulings: Types of rulings to exchange: Attribution of profits to a permanent establishment

Rulings related to attribution of profits to a permanent establishments should be automatically exchanged with relevant jurisdictions under Action 5.

HMRC does not as a general rule enter into discussions regarding the attribution of the profits to the permanent establishment, see INTM281030 and INTM480540.  Legal certainty about the tax treatment of future transactions is provided under the formal APA process (INTM422000).

Please see the guidance for exchange of APAs at IEIM541200.