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HMRC internal manual

International Exchange of Information Manual

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Exchange of a ruling under both Action 5 and the DAC: Overview

IEIM560010: Exchange of a ruling under both Action 5 and the DAC: Overview

Some rulings and APAs fall to be exchanged under both Action 5 and the EU DAC.  It is important that both requirements are considered when deciding with whom and when exchanges are to be made.  The template at INTM570900 covers the information required for both Action 5 and the DAC.

Given the differing requirements of Action 5 and the DAC it is expected that usually:

  • All rulings and APAs exchanged under Action 5 will also need to be exchanged under the DAC
  • Some rulings and all bilateral APAs will only be exchanged under the DAC

 

An example of an exchange under both Action 5 and the DAC is given at IEIM560020.