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HMRC internal manual

International Exchange of Information Manual

HM Revenue & Customs
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The DAC: Overview

IEIM550010: The DAC: Overview

The UK exchanges information with other EU Member States under the EU Directive on Administrative Cooperation in the field of taxation (2011/16/EU), known as the DAC. As well as being an instrument allowing exchange, the DAC also lists various mandatory situations where Member States must share information.

Unlike automatic exchanges made under other tax instruments in line with Action 5 (IEIM540010), or spontaneous exchanges (IEIM530010), rulings exchanged under the DAC are not provided directly to the other relevant jurisdictions, but instead are uploaded onto a central EU database (IEIM550300).

HMRC will be able to access this information in its risk assessment and enquiry work. Where, on reading the summary, a Member State can see that the ruling or APA is foreseeably relevant they can use the details provided, and if necessary request further details about the ruling from the originating State under the DAC.